WOLFIEK GROUP

PRIVACY POLICY AND DATA USE

1. WHO ARE WE?
We are WOLFIEK GROUP, specialists in air rifles, and we process your personal data as joint controllers. This means that we are jointly responsible for how we use and protect your data.

2. WHAT DO WE USE YOUR DATA FOR?
We will use your data (obtained online or in person), among other purposes, to manage your registration as a user, manage the purchase of products or services, answer your queries as well as, if you wish, send you our personalized communications.

3. WHY DO WE USE THEM?
We are authorized to process your data for different reasons. The main one is that we need to process them to execute the contract that you accept with us when registering and when making a purchase or enjoying any of our services or functionalities. We also use your data for other reasons, for example, toanswer your questions or send newsletters that you have requested to receive.

4. WHO DO WE SHARE YOUR DATA WITH?
We will share your data with service providers who help or support us, whether they are companies from the Group itself or external collaborators with whom we have reached an agreement.

5. YOUR RIGHTS.
You have the right to access, rectify or delete your personal data. In some cases, you also have other rights, for example, to object to our use of your data or to port it, as we explain in detail below.

We invite you to read our full Privacy and Cookies Policy below to understand in detail the use we will make of your personal data and the rights you have in relation to it.

In this Privacy and Cookies Policy you will find all the relevant information that applies to the use we make of the personal data of our clients and users, regardless of the channel or medium (online or in person) that you use to interact with us.

1. WHO IS RESPONSIBLE FOR THE PROCESSING OF YOUR DATA?

The persons responsible for the processing of your data are:

Wolfiek Group and Wolfiek partners, a company that currently operates in Spain selling compressed air products and accessories of different brands.

-Postal address: Pallars 101, 1-1. Barcelona, ​​Spain

-Data Protection Officer email: info@wolfiekgroup.com

2. FOR WHAT PURPOSE DO WE PROCESS YOUR PERSONAL DATA?

Depending on the products, services or features you wish to enjoy at any given time, we will need to process some data or others, which will generally be, as appropriate, the following:

Your identification data (for example, your name, surname, image, language and country from which you interact with us, contact information, etc.);economic and transactional information (for example, your payment or card details, information about your purchases, orders, returns, etc.);connection, geolocation and navigation data (for example, location data, device identification number or advertising ID);commercial information (for example, if you are subscribed to our newsletter),data about your tastes and preferences.

Remember that, when we ask you to provide your personal data to give you access to any functionality or service of the Platform, we will indicate some fields as mandatory, since they are data that we need to be able to provide you with the service or give you access to the functionality in question. Please note that if you choose not to provide us with this information, you may not be able to complete your registration as a user or you may not be able to enjoy those services or features.

In other cases, we may obtain information passively by using tracking tools, such as browser cookies or other similar technologies on our Platform or from communications we send you.

In certain cases, a third party may have provided us with information about you when using a feature or service on the Platform, for example, if they have sent you a gift card or if they send an order to your address.

In such cases, we will only process your data in relation to that feature or service, in accordance with the provisions of this Privacy and Cookies Policy. Depending on how you interact with our Platform, we will process your personal data for the following purposes:

1. To manage your registration and identification as a user of the Platform.

If you decide to register as a user on our Platform, we need to process your data to identify you as a user of the Platform and give you access to its different functionalities, products and services that are available to you as a registered user. You can cancel your registered user account by contacting us through Customer Service. We inform you that the data we collect about your activity, obtained through the different channels of the Platform, and which include your purchases, will remain linked to your account so that all the information can be accessed at once. For your identification on our Platform, it may be necessary for you to go through an identity verification process, for which you will be offered various methods. This process will guarantee that you are the owner of the contact information you are using.

2. For the development, fulfillment and execution of the sales or service contract that you have contracted with us on the Platform. This purpose includes the processing of your data mainly to:

- Contact you regarding updates or informative communications related to the functionalities, products or services contracted, including the sending of quality surveys on the products or services provided.

- Manage the payment of the products you purchase, regardless of the payment method used.

- Activate the necessary mechanisms in order to prevent and detect improper use of the Platform, for example, during the purchase and return process, as well as potential fraud against you and/or against Us. If we consider that the operation may be fraudulent or we detect abnormal behavior with indications of fraudulent use of our functionalities, products and services, this treatment may have consequences such as blocking the transaction or canceling your user account.

- Manage possible changes or returns once you have made a purchase and manage requests for information on the availability of garments, reservations of products through the Platform, depending on whether these options are available at any given time.

- For billing purposes and to make available to you the tickets and invoices for the purchases you have made on the Platform.

- Guarantee the use of other functionalities or services to the extent that they are available, such as the purchase, receipt, management and use of the Gift Card or Gift Ticket.

- Finally, we may process your data to comply with the legal obligations that apply.

3. To respond to requests or queries you make through customer service channels.We only process personal data that is strictly necessary to manage or resolve your request or query.

If you use the telephone channel, the call may be recorded to respond to your request and ensure its quality.

If available, and you decide to use WhatsApp as a channel to communicate with Customer Service, we recommend that you review your privacy settings and read WhatsApp's privacy policy for more detailed information on WhatsApp's use of the personal data of users who use its services.

If available, and you decide to communicate with Customer Service through the chat service of a social network or other partner, some of your data, such as your name or username, will be imported from your social network or partner account. You should also keep in mind that the data you enter into this service will be available to your social network or partner and will be subject to their corresponding privacy policies. Therefore, we recommend that you review your privacy settings and read the privacy policy of the social network or partner to obtain detailed information about the use they make of your personal data when using their services.

4. For marketing purposes. This purpose includes the processing of your data mainly to:

- Personalize the services we offer you and be able to make recommendations based on your interaction with us on the Platform and the analysis of your user profile (for example, based on your purchase and browsing history).

- To the extent that you subscribe to our Newsletter, we will process your personal data to manage your subscription, including sending you personalized information about our products or services through various means (such as email or SMS). Likewise, we may send you this information through push notifications if you have activated them on your device.

- Therefore, please note that this data processing involves the analysis of your user or customer profile to determine your preferences and therefore which products and services best fit your style when sending you information. For example, based on your purchase and browsing history (namely, based on the items you have clicked on), we will make suggestions about products that we think may interest you and, if you are a registered user, we will provide you with the "cart recovery" feature.

- Remember that you can unsubscribe from the Newsletter at any time and at no cost through the "Newsletter" section of the Platform, as well as through the instructions we provide you in each communication. If you do not wish to receive push notifications, you can deactivate this option on your device.

- Show you advertising on the Internet that you can see when you browse websites and apps, for example, on social networks. The advertising you see may be displayed randomly, but in other cases it is advertising that may be related to your purchase history, preferences and browsing.

- If you are a user of social networks, we may provide certain information to those with which we collaborate so that they can show you advertisements from our brand and, in general, offer you or other similar users advertising based on your profile on said social networks. If you want information about the use of your data and the functioning of advertisements on these social networks, we recommend that you review the information about your privacy on the social networks in which you participate.

- Additionally, we use your data to carry out measurement and segmentation analyses of the advertisements that we show to users on some of our partners' platforms. To do this, we collaborate with these third parties that offer us the necessary technology (for example, through cookies, pixels, SDKs) to use these services. Please note that, although we do not provide personal identification data to these partners, we do communicate some unique identifier to them (for example, the advertising identifier associated with the device, identifier of a cookie, etc.). If you want more information about this, please review our Cookie Policy. You can also reset your advertising identifier or disable the personalization of ads on your device by changing your preferences in the settings section of your device.

- Data enrichment: When we obtain your personal data from various sources, we may combine them in certain circumstances in order to improve our understanding of your needs and preferences in relation to our products and services (including for the purposes of analysis, generation of usage profiles, marketing studies, quality surveys and improving interaction with our customers). We refer, for example, to the combination of information that we can do if you have a registered account and, with the same email address or phone number linked to your account, you make purchases as a guest; or to automatically collected information (such as IP addresses, MAC addresses or metadata) that we can link to information that you have provided us directly through your activity on the Platform or in any of our stores (for example, information related to your purchases, whether in physical stores or in the online store, your preferences).

- Carry out promotional actions (for example, to run contests or send your list of saved items to the email address you provide). By participating in any promotional action, you authorize us to process the data you provide us with based on each promotional action and to communicate them through various means such as social networks or on the Platform itself. For each promotional action in which you participate, you will have available the legal bases where we will provide you with more detailed information about the processing of your data.

- Share on the Platform or through our social media channels photographs or images that you have shared publicly, provided that you give us your consent to do so.

5. Usability and quality analysis to improve our services:

If you access our Platform, we inform you that we will process your data for analytical and statistical purposes, that is, to understand the way in which users interact with our Platform and with the actions we can carry out on other websites and apps and thus be able to introduce improvements.

Likewise, we occasionally carry out quality actions and surveys aimed at finding out the level of satisfaction of our clients and users and detecting those areas in which we can improve.

3. WHAT IS THE LEGAL BASIS FOR THE PROCESSING OF YOUR DATA?

The legal basis that allows us to process your personal data also depends on the purpose for which we process it, as explained below:

1. Manage your registration as a user of the Platform and identification

The processing of your data is necessary for the execution of the terms that regulate the use of the Website and App. In other words, in order for you to register as a user on the Platform, we need to process your personal data, since otherwise we would not be able to manage your registration.

In the event that you choose to use access or login through a social network, the reason why we are authorized to process your data is the consent you give at the time of authorizing the transfer of your data from the social network.

2. Development, compliance and execution of the sales or services contract

The processing of your data is necessary for the execution of the sales or services contract that binds us to you.

In addition, we process your location data when you give us your consent, to offer you specific services through the website. We consider that we have a legitimate interest in carrying out the necessary verifications to detect and prevent possible fraud or fraudulent use of the Platform.

3. Customer Service

We consider that we have a legitimate interest in responding to the requests or queries that you submit to us through the various means of contact that exist. We understand that the processing of this data is also beneficial to you as it allows us to be able to serve you adequately and resolve the queries raised.

When you contact us, in particular, to manage incidents related to your order or the product/service purchased through the Platform, the processing is necessary for the execution of the purchase contract.

When your query is related to the exercise of the rights we inform you about below, or to claims related to our products or services, we are entitled to process your data if we comply with legal obligations.

In some cases related to product claims, it may be necessary for the data to be processed to guarantee the public interest in matters of public health.

4. Marketing

The legitimate basis for processing your data for marketing purposes is the consent you give us, for example: when you agree to receive personalized information through various means, when you authorize the sending of push notifications on your device, when you give your consent by configuring the cookies or privacy settings on your device, or when you accept the legal bases for participating in a promotional action; In order to offer you personalized services or show you personalized information, whether on our Platform or on that of third parties, as well as to carry out data enrichment, we consider that we have a legitimate interest in profiling the information we have about you (such as your browsing habits, preferences or purchase history) and the personal data you have provided us, such as age range or language, since we understand that the processing of this data is also beneficial to you because it allows you to improve your experience as a user and access information in accordance with your preferences.

5. Usability and quality analysis

We consider that we have a legitimate interest in analyzing the usability of the Platform and the degree of user satisfaction since we understand that the processing of this data is also beneficial for you because the purpose is to improve the user experience and offer a higher quality service.

4. HOW LONG WILL WE KEEP YOUR DATA?

The period of conservation of your data will depend on the purposes for which we process it, as explained below:

1. Manage your registration as a user of the Platform and identification

We will process your data for as long as you remain a registered user (that is, until you decide to delete your online account or your store profile).

2. Development, fulfillment and execution of the contract of sale or services

We will process your data for the time necessary to manage the purchase of the products or services, including possible returns, complaints or claims associated with the purchase of the particular product or service.

In some cases, we will only process the data until you decide, as is the case of the payment data that you have asked us to store for possible future purchases (if this functionality is available).

3. Customer Service

We will process your data for as long as necessary to attend to your request or petition, as well as for the periods established in the regulations that are applicable in each case.

4. Marketing

We will process your data until you unsubscribe or cancel your subscription to the newsletter. Likewise, we will show you personalized ads until you change the device, browser or cookie settings, which will revoke said permission.

5. Usability and quality analysis

We will process your data punctually during the time in which we proceed to carry out a specific quality action or survey or until we anonymize your browsing data.

Regardless of whether we process your data for the time strictly necessary to fulfill the corresponding purpose, we will subsequently keep them duly stored and protected for the time in which liabilities arising from the processing may arise, in compliance with the regulations in force at any given time.

5. WILL WE SHARE YOUR DATA WITH THIRD PARTIES?

In order to fulfill the purposes indicated in this Privacy and Cookies Policy, it is necessary that we give access to your personal data to Wolfiek Group entities and third parties that support us in the services we offer you, namely: financial entities, fraud detection and prevention entities, technology and analytics service providers, logistics, transportation and delivery service providers and collaborators or their associated establishments, customer service-related service providers, marketing and advertising-related service providers and collaborators, such as advertising agencies, advertising partners or social networks that, in certain cases, may act as joint controllers.

6. WHAT ARE YOUR RIGHTS WHEN YOU PROVIDE US WITH YOUR DATA?

We are committed to respecting the confidentiality of your personal data and to guaranteeing the exercise of your rights. The Joint Controllers have agreed that you can exercise them free of charge by writing to us at a single email address info@wolfiekgroup.com, simply indicating the reason for your request and the right you wish to exercise. If we consider it necessary to identify you, we may request a copy of a document proving your identity.

Likewise, we can offer you the possibility of exercising your rights and configuring your privacy preferences when using some of our services or by making specific channels available to you within our Platform.

In particular, regardless of the purpose or legal basis under which we process your data, you have the right to:

• Request access to the data we have about you. We remind you that if you are a registered user on the Platform, you can also consult this information in the section corresponding to your personal data.

• Ask us to rectify the data we already have. Remember that if you are a registered user on the Platform you can also access the section corresponding to your personal data in your account to modify or update your personal data. In any case, keep in mind that, by actively providing us with your personal data by any means, you guarantee that they are true and accurate and you undertake to notify us of any change or modification to them.

• Ask us to delete your data to the extent that they are no longer necessary for the purpose for which we need to process them as we have informed you above, or that we no longer have the legitimacy to do so.

• Ask us to limit the processing of your data, which means that in certain cases you can ask us to temporarily suspend the processing of the data or to keep them beyond the time necessary when you may need it.

If you have given us your consent for the processing of your data for any purpose, you also have the right to withdraw it at any time. Some of the ways in which you can withdraw your consent are explained in section 2, where we explain the purposes for which we process your data.

If you do not want information to be sent to third parties to show you advertisements, you have several means, such as changing preferences on your device, browser or cookie settings, reviewing the privacy policy and settings of the social networks on which you have a profile or sending us an email with your request to the address mentioned above.

When our legitimacy for the processing of your data is your consent or the execution of the contract, as explained in section 3, you will also have the right to request the portability of your personal data.

This means that you will have the right to receive the personal data that you have provided to us in a structured, commonly used and machine-readable format, in order to be able to transmit it to another entity directly, whenever technically possible.

Furthermore, when the processing of your data is based on our legitimate interest, you will also have the right to object to the processing of your data.

Finally, we inform you of your right to file a claim with the relevant data protection control authority, in particular, with the Spanish Data Protection Agency (https://www.agpd.es/portalwebAGPD/index-ides-idphp.php).

7. WHAT HAPPENS IF YOU PROVIDE US WITH DATA OF THIRD PARTIES OR IF A THIRD PARTY HAS PROVIDED US WITH YOUR DATA?

We offer features or services that require us to process the personal data of a third party that you as a user or customer provide to us, such as for the activation and sending of the Gift Card or the management of the Gift Ticket request (if these features are available), or when you authorize a third party to receive an order. If you provide us with Personal Data of third parties or if it is necessary for them to provide it to us in order for a third party to collect an order on your behalf, you guarantee that you have informed them about the purposes and the way in which we need to process their personal data.

If a third party has provided us with your data or you have provided it yourself as a result of a feature or service requested by one of our users, we will use it to manage the feature or service being developed in each case, within the purposes set out in this Privacy and Cookies Policy, the link to which we usually include in our communications.

8. CHANGES TO THE PRIVACY AND COOKIES POLICY

We may modify the information contained in this Privacy and Cookies Policy when we deem it appropriate. If we do so, we will notify you in different ways through the Platform (for example, through a banner, a pop-up or a push notification), or we will even communicate it to your email address when the change in question is significant for your privacy, so that you can review the changes, evaluate them and, where appropriate, oppose or unsubscribe from any service or feature. In any case, we suggest that you review this Privacy and Cookies Policy from time to time in case there are minor changes or we introduce any interactive improvements, taking advantage of the fact that you will always find it as a permanent point of information on our Website and our App.

9. INFORMATION ABOUT COOKIES

We use cookies and similar devices to facilitate your navigation on the Platform, to know how you interact with Us and, in certain cases, to be able to show you advertising based on your browsing habits. Please read our Cookies Policy to learn more about the cookies and similar devices we use, their purpose and how to manage your preferences, as well as other information of interest.

COOKIES POLICY

In this Cookies Policy you will find information about the use we make of cookies and similar devices that are installed on the terminals of our clients and users. Sometimes, the use of cookies may be related to the processing of personal data, so we recommend that you consult our Privacy Policy, accessible on our Platform, if you want information about how we use the personal data of our clients and users, how to exercise your rights, or the terminology we use to refer to our Platforms (Websites).

INFORMATION ABOUT COOKIES

What is a Cookie?

A Cookie is a small text file that a website, app or other platform stores on your computer, tablet, smartphone or any other similar device, with information about your browsing or use, such as a tag that identifies your device.

Cookies are necessary, for example, to facilitate navigation and to know how users interact with the platforms, so that they can be improved.

They are also very useful to be able to offer advertising according to the user's preferences, as well as for other purposes detailed below. Cookies do not harm your computer or device.

When we talk about "Cookies" we also refer to other similar technologies for installing and/or collecting information on or about your device (such as flash cookies, web beacons or bugs, pixels, HTML5 (local storage), and SDK technologies for app formats). Likewise, the term "Cookies" also applies to the use of fingerprinting techniques, that is, those techniques for combining information that help us identify your device. Sometimes, these technologies work together with cookies to collect and store information, either to provide you with certain features or services on our Platform, or to show you advertising on third-party platforms, taking into account your browsing.

This explanation is a general example of what is meant by Cookies for informational purposes only. The Cookies that we use specifically are detailed in the cookie configuration panel accessible on our Platform.

What types of Cookies exist?

Please review this section that provides an overview of the types of Cookies that can be used in an online environment.

Depending on the owner of the Cookies, they can be classified as:

a. Own Cookies: These are those that are sent to the user's computer or device from a computer or domain managed by the publisher itself, and from which the platform or service requested by the user is offered.

b. Third-party Cookies: These are those that are sent to the user's computer or device from a computer or domain that is not managed by the publisher, but by another entity that processes the data obtained through the cookies.

Depending on the purpose of the Cookie, they can be classified as:

a. Strictly necessary (technical) cookies: These are cookies that allow the user to navigate through a website, platform or application and use the different options or services that exist therein, such as, for example, controlling traffic, identifying data or the session, accessing restricted sections or content, remembering the elements that make up an order, carrying out the purchase process of an order, managing payment, controlling fraud linked to the security of the service, using security elements during navigation, making the request for registration or participation in an event, storing content for the dissemination of videos or sound, enabling dynamic content (for example, animation for loading a text or image) or sharing content through social networks. Technical cookies, being strictly necessary, are downloaded by default when they allow the platform to be displayed or the service requested by the user to be provided.

b. Functionality or personalization cookies: These cookies are those that allow information to be remembered so that the user accesses the service or platform with certain characteristics that can differentiate their experience from that of other users, such as, for example, the language, the number of results to be displayed when the user performs a search, the appearance or content of the service depending on the type of browser used by the user or the region from which they access the service, etc. Not accepting these Cookies may result in slow performance of the website or poorly adapted recommendations.

c. Analysis cookies: These are those that allow the number of users, the sections visited on the platform and how they interact with it to be quantified, in order to carry out the measurement and statistical analysis of the use made by users, in order to introduce improvements based on the analysis of the data on the use made by users of the platform or service.

d. Behavioral advertising cookies: These are those that store information on the behavior of users obtained through the continued observation of their browsing habits, which allows a specific profile to be developed to display advertising based on it. These cookies allow the management, in the most efficient way possible, of the advertising spaces that, where appropriate, the editor has included directly or in collaboration with third parties.

What are Cookies used for on our Platform?

Cookies are an essential part of how our Platform works. The main objective of our Cookies is to make your browsing experience more comfortable and efficient. For example, they are used to remember your preferences (language, country, etc.) during browsing and on future visits. We also use our Cookies to continuously improve our services and Platform, as well as to be able to offer personalized advertising based on your browsing habits.

The information collected in the Cookies also allows us to improve our Platform by estimating statistical data and usage patterns (number of visits, most visited sections, visit time, etc.), to statistically understand how users interact with the Platform in order to improve our services, as well as to adapt the Platform to your individual interests, speed up searches, etc.

Occasionally, we may use Cookies to obtain information that allows us to display advertising based on the analysis of your browsing habits (products visited, sections consulted, etc.) from our Platform, third-party platforms, or by any other means.

In any case, we never store sensitive information such as passwords, credit or debit card details, etc. in the Cookies we use.

How can I manage the use of Cookies on this Platform?

In the Cookies configuration panel accessible at all times on our Platform, you can obtain all the information about the Cookies used by this Platform, together with information about the purpose, duration and management (own or by third parties) of each of them, so that you can manage the activation and deactivation of the use of those Cookies that are not strictly necessary for the operation of the Platform.

Alternatively, if you are browsing the Internet, you can disable the use of Cookies in your browser. We will show you how to do this in the most popular browsers:

• Google Chrome

• Internet Explorer

• Mozilla Firefox

• Safari

This possibility of avoiding the use of Cookies can be carried out at any time.

Please note that both your management of the Cookies settings panel and your option to reject Cookies are specific to each browser you are using. Therefore, if you choose to configure Cookies in one way on one device and you want your option to apply similarly to another device, you must activate the same option for that other device.

As an additional step, with respect to third-party Cookies for the purpose of providing advertising based on your interests, please note that certain third parties may be members of one of the following self-regulatory programs for online behavioral advertising, with the corresponding opt-out options:

• Network Advertising Initiative (NAI) - http://www.networkadvertising.org/choices/

• Google Analytics - https://tools.google.com/dlpage/gaoptout

Who uses the information stored in Cookies?

The information stored in the Cookies on our Platform is used exclusively by us, except for those identified in section 2 as “Third Party Cookies”, which are used and managed by external entities to provide us with services aimed at improving our services and the user experience when browsing our Platform. More information in the Cookies configuration panel accessible at all times on our Platform.

For more detailed information on the processing of your personal data in our collaboration with third parties and those subject to international data transfers, we recommend that you read our Privacy Policy accessible on our Platform, and the privacy policies / privacy settings of these third party collaborators accessible through their platforms.