PRIVACY POLICY OF DAKIA UMUSIC HOSPITALITY LLC

This Privacy Policy (hereinafter, the "Policy") aims to regulate the personal data processing activities carried out by the entities of the DAKIA UMUSIC HOSPITALITY, LLC group, listed below (hereinafter, "UMusic Hotels") concerning individuals (hereinafter, "Users") through the website www.umusic-hotels.com (hereinafter, the "Website").

UMusic Hotels Entities List:

• DAKIA UMUSIC HOSPITALITY LLC, Tax Number: 61-1927724
• DAKIA UMUSIC HOSPITALITY MADRID, S.L.U., Tax Number (NIF): B10716439

1. Identity and Contact Information of the Data Controller

In compliance with applicable data protection regulations, UMusic Hotels informs Users that their personal data will be included in a file duly registered in the Register of Processing Activities owned by UMusic Hotels.

Additionally, Users are informed that the Data Controller for their personal data is UMusic Hotels, whose contact details are listed at the beginning of this Policy.

If you have any questions regarding data protection, you can contact UMusic Hotels’ Privacy Officer via email at dataprivacy@umusic-hotels.com.

2. What is the Purpose of Processing Users’ Personal Data, and What is the Legal Basis?

Personal data collected through the Website and the App will be processed for the following purposes:

• Track User navigation on the Website through cookie installation, with the legal basis being the User’s consent;
• Manage reservations (including payment processing, if applicable), handle requests, and send confirmations, documentation, modifications, or cancellations related to them, based on the contractual relationship between the parties;
• Digitally manage guest check-in before arrival, based on the contractual relationship between the parties;
• Manage subscriptions and subsequent commercial communications (including newsletters) about UMusic Hotels services, news, and updates, as well as handle opt-out requests, based on the User’s consent;
• Handle inquiries and requests received through the Website's ChatBot, based on the implementation of pre-contractual measures at the User’s request;
• Conduct satisfaction surveys during and after the hotel stay regarding service quality, based on UMusic Hotels’ legitimate interest in analyzing service quality;
• Manage the provision of the contracted accommodation service and additional services during the stay through the App, based on the contractual relationship and the User’s consent, respectively;
• Handle and resolve inquiries, requests, complaints, incidents, or suggestions through the contact form on the Website and/or the App, based on the User’s consent;
• Process job applications and résumés to fill vacancies or consider unsolicited applications, based on the User’s consent;
• Send information and reminders related to unfinished reservations, based on UMusic Hotels’ legitimate interest in direct marketing; and
• Show Users offers based on their location, based on the User’s consent given when authorizing UMusic Hotels to use the location data of their mobile device via the relevant pop-up.

3. How Long Will UMusic Hotels Process Users’ Personal Data?

In compliance with applicable regulations, UMusic Hotels will process Users’ personal data until it is no longer necessary for the purpose for which it was collected or until the User requests deletion, objects, or withdraws their consent (if required for the purpose). Once this period ends, UMusic Hotels will keep the data duly blocked for the applicable retention periods to address potential legal liabilities. Blocking data means UMusic Hotels can only process it to address liabilities arising from the processing. Personal data will be deleted once the specified retention periods have expired.

4. Security Measures

UMusic Hotels has implemented the legally required security measures for the protection of Personal Data, installing all technical and organizational means to ensure the security of Users’ Personal Data and prevent its destruction, loss, misuse, alteration, unauthorized access, or theft. These measures are determined considering factors such as the scope, context, and purposes of the processing, the state of technology, and existing risks.

5. Source of Personal Data

UMusic Hotels collects personal data directly from its Users. However, some User data may be obtained from third parties, including:

• Companies within the UMusic Hotels group;
• Aggregators such as Booking.com and other online accommodation booking platforms, which may provide: (i) User contact details; (ii) information about the booked reservation (date, room type, additional services, etc.);
• Travel agencies through which Users book UMusic Hotels services, which may provide: (i) User contact details; (ii) information about the booked reservation (date, room type, additional services, etc.).

6. Recipients of Personal Data

Users’ data may be shared with third parties, including:

• Companies within the UMusic Hotels group for the purposes mentioned above;
• Competent authorities and courts when necessary to comply with legal obligations or for the defense and/or formulation of claims.

Additionally, for the management of the purposes listed above, subcontracted entities may access personal data on behalf of UMusic Hotels to provide a service or assist in managing the Website. These third parties are Data Processors, and UMusic Hotels ensures their access complies with current regulations and follows UMusic Hotels’ instructions.

7. International Data Transfers

For the purposes listed above, recipients of personal data may access UMusic Hotels data from third countries outside the European Economic Area (EEA). In such cases, UMusic Hotels ensures valid mechanisms are in place for international data transfers, such as:

• Transfers to countries recognized as adequate by the European Commission; or
• Transfers to non-adequate countries based on European Commission-approved Standard Contractual Clauses.

Users may request more information about these mechanisms by contacting dataprivacy@umusic-hotels.com.