PRIVACY AND DATA PROTECTION POLICY

PDC DEVELOPMENT COMPANY LLC (“PDC”), as the entity responsible for this website, hereby informs users of the processing of their personal data in compliance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”), Spanish Organic Law 3/2018 on Data Protection and Digital Rights (LOPDGDD), and Law 34/2002 on
Information Society Services and Electronic Commerce (LSSI-CE).

1. Data Controller
The data controller is PDC DEVELOPMENT COMPANY LLC, with its registered office at
[insert full U.S. address] and Tax ID: __________.

2. Data Collected
The personal data collected are strictly limited to:
First and last name
Email address
Banking/payment details strictly necessary for ticket purchase and validation

3. Purpose of Processing
Personal data will be processed for the following purposes:
1. Managing the purchase of tickets for the Reserve Cup Marbella 2025, including
payment processing, order confirmation, and electronic ticket delivery.
2. Guaranteeing traceability of the transaction and resolving any purchase-related
issues.
3. If the user provides explicit consent, the data (email address) may also be used
for sending commercial communications regarding future editions of Reserve Cup or other sports events of interest, for the maximum period permitted by law.

4. Legal Basis
The processing of data is based on:
Performance of a contract (Art. 6.1.b GDPR): managing the purchase and
delivery of tickets.
 Explicit consent of the data subject (Art. 6.1.a GDPR and Art. 21 LSSI-CE):
sending commercial communications.

5. Data Disclosure and Recipients
Personal data may be disclosed to: ONEBOX IBÉRICA, S.L., with registered office at Via Augusta 21-23, 7th floor, 08006 Barcelona, as the ticketing technology provider, acting as data processor or joint controller for the purpose of managing ticket sales and distribution. Service providers (IT, hosting, communications, etc.) under agreements ensuring GDPR compliance. Public administrations or competent authorities where required by law.

6. International Data Transfers
Since PDC is established in the United States, personal data may be subject to
international transfer to a country outside the European Economic Area (EEA).
Such transfer is legitimized by:
The performance of the contract (ticket purchase and delivery).
The implementation of European Commission Standard Contractual Clauses, along with appropriate technical and organizational measures to ensure a level of protection essentially equivalent to that required in the EU.

7. Data Retention
Personal data will be retained for a maximum of five (5) years after the conclusion of the
event or until the expiration of any legal liability arising therefrom. Data processed for
commercial communication purposes will be retained until the user withdraws consent or
until the maximum period legally permitted.

8. Data Subject Rights
Data subjects may exercise the following rights at any time:
Access
Rectification
Erasure
Restriction of processing
Data portability
Objection
Withdrawal of previously granted consent
These rights may be exercised by contacting:
Email: ________________

EU Representative: 380 AROUND MARKETING S.L., NIF B86853579, Address: Vía de las Dos Castillas nº 33, Ática VI, 2nd floor, D1, Pozuelo de Alarcón, Madrid (Spain) In addition, users have the right to lodge a complaint with the Spanish Data Protection
Agency (www.aepd.es).

9. Commercial Communications (LSSI-CE)
In compliance with the LSSI-CE, users will only receive commercial communications if they have given their prior and explicit consent. Each message will include a clear, free, and simple mechanism for unsubscribing or objecting at any time.

10. Modifications to the Privacy Policy
PDC reserves the right to modify this Privacy Policy to reflect legislative, jurisprudential, or industry practice changes, while committing to notify users in advance of any modifications
that may affect them.