PRIVACY POLICY – ADDURNO.COM PORTAL

This Data Protection Policy has been drawn up in accordance with the regulations in force in Andorra, Qualified Law 29/2021, of 28 October, on the protection of personal data (hereinafter, "LQPD"), and Regulation (EU) 2016/679 of the European Parliament and of the Council, of 27 April 2016 (hereinafter, "GDPR").

SEAFRONT CAPITAL TECHNOLOGIES, S.L.U. is committed to protecting the privacy of every user of our web portal and our services. This privacy policy provides users with information regarding the processing of their personal data collected and processed through our portal.

1. IDENTIFICATION AND CONTACT DETAILS OF THE DATA CONTROLLER

• Owner: SEAFRONT CAPITAL TECHNOLOGIES, S.L.U.
• NRT: L-716181-P
• Registered address: Carrer del Fener 11-13, Andorra la Vella AD500, Andorra
• Email: [email protected]
• Web portal: www.addurno.com
• Activity: Real estate advertising portal specialised in seafront properties in Spain, Portugal and Italy

2. PERSONAL DATA WE COLLECT

At ADDURNO we collect and process the following personal data of users:

2.1. Browsing data

When you visit our portal, we automatically receive the URL of the site you come from and the site you visit when you leave our portal. We also receive your computer's Internet protocol address (IP address), the type of browser you are using, and the day and time at which the connection is established and ended. We use this information to analyse overall trends and improve the service. In addition, we automatically collect other personal data while you browse the portal, as indicated in our Cookie Policy.

This analysis is carried out, where applicable, in aggregate form and for statistical purposes.

Where the use of analytical cookies requires consent, such processing will only take place after your acceptance in accordance with the Cookie Policy.

2.2. Data you provide to us

When you contact us, request property viewings or subscribe to our services, we collect:

• First name and surname
• Email address
• Contact telephone number
• Property search preferences
• Postal address (optional)
• Information provided in contact or viewing request forms
• Recordings of telephone calls held with our team, when the user contacts us or is contacted by telephone

Data marked as mandatory are necessary to properly provide our services and manage the requests made by the user. Optional data are requested solely to improve user care and experience.

Data are collected through the portal's forms, direct communications from the user (including telephone communications, which may be recorded) and, where applicable, through the mechanisms described in the Cookie Policy.

3. PURPOSE OF PROCESSING

SEAFRONT CAPITAL TECHNOLOGIES, S.L.U. uses your personal data for the following purposes:

• To manage our web portal and improve the user experience
• Request management: To process requests for information and property viewings
• Coordination with agencies: To share information with partner real estate agencies in order to coordinate viewings and manage requests
• To contact and communicate with you
• Record of transactions: To record telephone communications in order to document the requests, conditions and arrangements made, ensure service quality and have evidence of operations and agreements
• Commercial communications: To send information about properties, services, products, offers or promotions that may be of interest to you (with prior consent)
• Invoicing: To issue invoices for the advertising access service provided
• Service improvement: To analyse the use of the portal in order to improve our services, products and web portal
• Legal compliance: To comply with legal and tax obligations
• To protect and exercise our rights or respond to claims of any kind
• To investigate and defend ourselves against any claim or complaint by third parties; to investigate and protect ourselves against fraudulent acts, as well as to protect the security of our services

4. LEGAL BASIS FOR PROCESSING

The legal basis for the processing of your personal data is as follows:

• Performance of a contract or application of pre-contractual measures: To manage requests for information, viewing requests and the provision of the advertising service requested.
• User consent: For sending commercial communications, newsletters or other promotional communications, which will be requested expressly and separately in each case.
• Compliance with legal obligations: To comply with applicable legal, tax, accounting and regulatory obligations.
• Legitimate interest: To improve the security of the portal, prevent fraudulent use, improve our services and defend our rights, always respecting the fundamental rights and freedoms of the user.

The processing of telephone call recordings is based on the performance of pre-contractual measures requested by the user and on the legitimate interest of SEAFRONT CAPITAL TECHNOLOGIES, S.L.U. in documenting its transactions, ensuring service quality and establishing, exercising or defending claims.

5. RECIPIENTS OF DATA AND DISCLOSURE

We process your personal data confidentially in accordance with the LQPD and the GDPR. Your personal data may be disclosed to:

• Partner real estate agencies: To coordinate viewings and manage requests for information about advertised properties
• Technology service providers: Hosting, web maintenance, email marketing (under confidentiality agreements and appropriate security measures)
• Competent authorities: Where required by law, in compliance with a legal or regulatory obligation, in accordance with applicable regulations

ADDURNO does NOT sell or transfer personal data to third parties for commercial purposes.

6. INTERNATIONAL DATA TRANSFERS

Andorra has an adequacy decision recognised by the European Union, which guarantees a level of personal data protection equivalent to that required by the GDPR. Therefore, data processing carried out from the Principality of Andorra does not constitute an international data transfer in the restrictive sense.

In the event that, exceptionally, data transfers were made to other countries that do not have an adequacy decision, such transfers would be carried out by adopting the appropriate safeguards provided for in the applicable regulations (such as Standard Contractual Clauses or other recognised legal mechanisms).

7. COMMERCIAL COMMUNICATIONS / NEWSLETTER

We will only send you commercial communications or newsletters if you have given us your explicit consent to do so. You may revoke this consent at any time via the unsubscribe link included in each communication or by contacting us at [email protected].

8. PROFILING AND AUTOMATED DECISIONS

We inform you that SEAFRONT CAPITAL TECHNOLOGIES, S.L.U. will under no circumstances carry out profiling or make automated decisions that produce legal effects on you or similarly significantly affect you.

9. ACCURACY AND UPDATING OF DATA

It is important that the personal data we hold about you are lawful, adequate, relevant, accurate and up to date. You are responsible for the accuracy of the information you provide to us and must inform us of any change in the information provided.

Data provided that do not meet the aforementioned requirements shall exempt SEAFRONT CAPITAL TECHNOLOGIES, S.L.U. from liability.

The user undertakes and is obliged to communicate any future change or modification of their personal data, adapting them, accordingly, to their actual situation.

10. DATA RETENTION PERIOD

We will only retain your personal data for as long as necessary to fulfil the purposes for which we collected them, including in compliance with a legal or regulatory obligation, and where applicable, for as long as you do not withdraw your consent.

Specifically:

• Active user data: For as long as a commercial or contractual relationship exists
• Lead/enquiry data: Up to 3 years from the last interaction, unless you request deletion
• Invoicing data: For the legally required period (minimum 5 years under applicable tax regulations)
• Telephone call recordings: These will be retained for the duration of the relationship or transaction to which they relate and, subsequently, duly blocked for a maximum period of 5 years, corresponding to the limitation period for legal actions that may arise from the documented transactions, exclusively at the disposal of the competent authorities and for the establishment, exercise or defence of claims. In the event of an ongoing dispute, claim or proceeding, the recordings concerned will be retained for the duration of such proceeding and any appeals.

Once the indicated periods have elapsed, the data will be deleted or duly blocked and kept solely at the disposal of the competent authorities and for addressing possible legal liabilities.

11. SECURITY MEASURES

We implement appropriate technical and organisational security measures suited to the personal data we process, in compliance with the legal requirements laid down by the LQPD and the GDPR.

When applying security measures, SEAFRONT CAPITAL TECHNOLOGIES, S.L.U. takes into account the following factors: the nature, scope, context and purposes of the processing, as well as the risks of varying likelihood and severity for the rights and freedoms of natural persons.

ADDURNO has implemented appropriate measures to guarantee the security of personal data and prevent their alteration, loss, unauthorised processing or access, taking into account the state of technology, the nature of the data stored and the risks to which they are exposed.

12. USER RIGHTS

In relation to the data collected on this portal, you may exercise your rights of:

• Access: To know what personal data we hold about you
• Rectification: To correct inaccurate or incomplete data
• Erasure (right to be forgotten): To request the deletion of your data
• Objection: To object to the processing of your data for specific purposes
• Restriction of processing: To restrict processing in certain circumstances
• Portability: To receive your data in a structured format and transfer them to another controller
• Withdrawal of consent: At any time, without affecting the lawfulness of prior processing
• Not to be subject to automated individual decisions

To exercise these rights, the user may contact ADDURNO through the means indicated below. Additional documentation to verify the identity of the applicant may only be requested where there is reasonable doubt about it.

The request may be made by:

• Email: [email protected]
• Post: SEAFRONT CAPITAL TECHNOLOGIES, S.L.U., Carrer del Fener 11-13, Andorra la Vella AD500, Andorra
• Contact form at www.addurno.com

Likewise, you have the right to lodge a complaint regarding the use that SEAFRONT CAPITAL TECHNOLOGIES, S.L.U. makes of your personal data with the Andorran Data Protection Agency (APDA) or the competent supervisory authority according to your place of residence.

13. PROTECTION OF MINORS

The ADDURNO portal is aimed exclusively at persons over 18 years of age. Data of minors are not knowingly collected. If we detect that we have collected data of a minor, we will proceed to delete them immediately.

ADDURNO reserves the right to ask any user for an official document showing their age and an identifying photograph in order to continue with the service.

14. INTELLECTUAL AND INDUSTRIAL PROPERTY

All elements appearing on the portal, as well as the structure, design, source code, applications, graphic designs, photographs, texts, domain names and trademarks are the property of SEAFRONT CAPITAL TECHNOLOGIES, S.L.U. or, where applicable, of third parties who have assigned the corresponding rights of use, and are protected by intellectual and industrial property regulations.

The user may only use the material appearing on the portal for their personal and private use. Use for commercial purposes or any other use that is not personal and private is prohibited without the prior written consent of SEAFRONT CAPITAL TECHNOLOGIES, S.L.U.

15. LINKS TO THIRD-PARTY WEBSITES

On this portal, the user may find links leading to websites independent of ADDURNO. SEAFRONT CAPITAL TECHNOLOGIES, S.L.U. is not responsible for the content accessed via said links, nor for the quality, reliability, accuracy or truthfulness of the information or services, nor for any modifications made to them, nor for their technical availability.

16. EXCLUSION OF WARRANTIES AND LIABILITY

ADDURNO does not guarantee the availability, access and/or continuity of operation of the portal and its services. Nor shall it be liable, within legal limits, for damages caused to the user as a result of the unavailability, access failures and lack of continuity of the portal and its services.

SEAFRONT CAPITAL TECHNOLOGIES, S.L.U. shall not be liable for damages of any kind caused to the user as a result of the presence of viruses or other elements in the contents and services of the portal that may cause alterations to the user's computer system.

17. CHANGES TO THE PRIVACY POLICY

SEAFRONT CAPITAL TECHNOLOGIES, S.L.U. reserves the right to modify this Privacy Policy to adapt it to legislative or case-law developments or changes in the services.

Any modification will be published on the portal with an indication of the date of the last update. We will notify you of any changes on our portal and in this Data Protection Policy.

If you continue to use our services after such an update, you will be deemed to accept the new terms. If you do not accept the update, we would appreciate you letting us know and we will delete your personal data (except where it is necessary to retain them in compliance with legal or regulatory obligations) and you will not be able to continue using our services.

18. ACCEPTANCE

Accessing the portal and/or using it in any way confers the status of user of the portal and implies full and unreserved acceptance of each and every one of the conditions set out in this Privacy Policy.

19. APPLICABLE LAW AND JURISDICTION

This Privacy Policy is governed by Andorran law (Qualified Law 29/2021 on the protection of personal data) and the GDPR (EU) 2016/679, without prejudice to the mandatory consumer protection rules applicable according to the user's place of residence.

Any dispute in relation to this portal shall be settled before the competent jurisdiction in accordance with the applicable regulations, with the parties submitting to the corresponding courts under the legislation in force.

20. CONTACT AND COMMUNICATIONS

For any enquiry about this Privacy Policy or to exercise your rights, you can contact us through:

• Email: [email protected]
• Web portal: www.addurno.com (contact form)
• Postal address: SEAFRONT CAPITAL TECHNOLOGIES, S.L.U., Carrer del Fener 11-13, Andorra la Vella AD500, Andorra

SEAFRONT CAPITAL TECHNOLOGIES, S.L.U. may communicate with the user by post to the address provided, by email, by telephone or by any other public means of communication. All communications made by these means shall be deemed validly effected.

The user declares that the data provided are true, exact, correct and accurate, undertaking to notify SEAFRONT CAPITAL TECHNOLOGIES, S.L.U. of any modification or change in their notification and contact details.

21. USE OF ARTIFICIAL INTELLIGENCE

ADDURNO uses artificial intelligence systems as a support tool in the operation of the portal, in particular for the generation and translation of published content, descriptions and information, as well as for image processing and sorting. This content is subject to human oversight; nevertheless, it may contain errors or inaccuracies, and is therefore purely indicative and has no contractual value.

The artificial intelligence systems used are not employed to make automated decisions within the meaning described in section 8 of this Policy. Users' personal data are not used to train artificial intelligence models.

The portal may make available to users a conversational virtual assistant based on artificial intelligence. Said assistant identifies itself as such in the conversation interface itself. The responses it provides are generated automatically, may contain errors or inaccuracies and are purely informative, without constituting professional advice or generating any contractual commitment on the part of ADDURNO. Conversations held with the virtual assistant may be processed for the purpose of dealing with the queries raised and improving the quality of the service, in accordance with the provisions of this Privacy Policy.

For any enquiry related to the use of artificial intelligence on the portal, the user may contact the channels indicated in section 20.

Last updated: August 2026

SEAFRONT CAPITAL TECHNOLOGIES, S.L.U.
NRT: L-716181-P
Carrer del Fener 11-13
Andorra la Vella AD500, Andorra
Email: [email protected]
www.addurno.com