Last updated: 28 June 2026

1. DATA CONTROLLER

The controller of the personal data collected on WAGU Partners (https://www.wagu-partners.com) is:

- Owner: Frank Walter

- Tax ID (NIF): Z3324853-R

- Address: Barraques del Figuero No. 1, Torre Oceanis P75, 46024 Valencia

- Email: office@wagu-partners.com

- Telephone: +34 679 651 412

- Website: https://www.wagu-partners.com

- Data Protection Officer (DPO): office@wagu-partners.com

In accordance with Regulation (EU) 2016/679, the General Data Protection Regulation (GDPR), and Organic Law 3/2018 on the Protection of Personal Data and guarantee of digital rights (LOPDGDD), we inform users about how their personal data are processed.

2. WHAT DATA DO WE PROCESS AND FOR WHAT PURPOSES?

We process the personal data that users voluntarily provide (such as first name, surname, email address, telephone number and the content of their messages), as well as browsing data, for the following purposes:

1. To receive, manage and respond to enquiries, requests or communications that users submit via the forms or contact channels available on the website.

2. To send commercial information, updates and newsletters by electronic means, but only where the user has given explicit consent.

We do not create user profiles, nor do we make automated decisions that produce legal effects or similarly significant effects for the user.

3. LEGAL BASIS FOR PROCESSING

The legal bases for processing your data are:

• Your consent when you voluntarily provide your data (Art. 6(1)(a) GDPR).

• Your explicit consent to receive commercial communications, which you may withdraw at any time (Art. 6(1)(a) GDPR and Art. 21 LSSI).

• The legitimate interest of the Owner in maintaining the security of the website and in responding to communications received (Art. 6(1)(f) GDPR).

4. RETENTION PERIOD

We will retain your data for as long as our relationship with you continues and, once it ends, for the periods required under applicable law to address any potential liabilities. When the data are no longer necessary for these purposes, they will be securely deleted using appropriate technical and organisational measures.

5. DATA RECIPIENTS

To provide our services, your data may be disclosed to the following third party, which acts as a data processor and with whom a data processing agreement has been concluded in accordance with Art. 28 GDPR:

Bullmer GmbH

Your data will not be passed on to any other third parties unless there is a legal obligation to do so.

6. USER RIGHTS

You may exercise the following rights at any time, free of charge, by contacting office@wagu-partners.com and indicating which right you wish to exercise, together with a copy of a valid identity document:

• Right of access: to find out whether we process your data and, if so, which data we hold.

• Right to rectification: to correct inaccurate or incomplete data.

• Right to erasure (“right to be forgotten”): to request the deletion of your data.

• Right to object: to object to the processing of your data in certain circumstances.

• Right to restriction of processing: to request that we limit the processing of your data in the cases provided for by law.

• Right to data portability: to receive your data in a structured, commonly used and machine‑readable format, and to transmit them to another controller where technically feasible.

• Right to withdraw consent: to withdraw the consent you have given at any time, without affecting the lawfulness of processing carried out prior to withdrawal.

If you believe that your rights have not been properly respected, you may lodge a complaint with the Spanish Data Protection Agency (AEPD), C/ Jorge Juan 6, 28001 Madrid — www.aepd.es.

7. DATA SECURITY

The Owner implements the technical and organisational measures necessary to ensure an appropriate level of security for your data and to prevent their alteration, loss or unauthorised processing or access, in accordance with Art. 32 GDPR. The website uses an SSL certificate to encrypt communications between the user’s browser and the server.

8. ACCURACY OF THE DATA

Users guarantee that the data they provide are truthful, accurate and up to date, and they undertake to inform us of any changes. Users are also responsible for the accuracy of any third‑party data they provide and must confirm that they have informed such third parties about the disclosure of their data.

9. CHANGES TO THIS PRIVACY POLICY

The Owner reserves the right to modify this Privacy Policy to adapt it to legislative developments or changes in its activities. Any updates or amendments will be published on this page.