PRIVACY POLICY OF "CUPRA TRIBE APP" OF SEAT, S.A.
By means of the present Privacy Policy, we would like to inform you about the collection, processing and use of your personal information as CUPRA Masters when using the CUPRA Tribe App (hereinafter, the “App”). Who is the data controller? The Data Controller for the processing of your personal data is SEAT, S.A (hereinafter, CUPRA), tax identification number A-28049161, Autovía A-2, Km. 585, Martorell (Barcelona), whose Data Protection Officer’s can be contacted at the following email: dataprotection@seat.es. What’s the purpose of the processing of your personal data? At CUPRA we process the personal information provided to us, as well as all information collected by the App, for the following main purposes: 1.To manage your registration as a user of the App in the role that will be taken into account as CUPRA Master. 2. To grant you access to the information and contents or services offered through the App. Access to the App will allow you to perform the following actions, including but not limited to: •Participate in social wall publications and comment on images. •Obtain basic information about other CUPRA Masters registered in the App. •Access and download all of the documents made available through the App in order to promote the brand. •View reminders of important events and appointments. 3.Clarify any doubts and queries raised through the “Contact” form. What is the legal basis for the processing of your personal data? The legal basis for processing your data is the execution of the service contract for the App, as outlined in the Conditions of Use. It is necessary to process your information for the purposes indicated above in order to render the services included in the App. Additionally, CUPRA processes your personal data in the context of product improvement. This involves analysing your usage data that is generated when you use the app. The legal basis for this is the consent of the user. What type of personal data are processed? As part of rendering the services offered by the App, and limited to the purposes indicated above, CUPRA processes your identification information and professional contact information, as well as any information you provide to us through the App, such as usage data. Who are the recipients of my personal data? CUPRA will not share your personal information with third parties unless required to do so in order to meet its legal obligations. Moreover, we wish to inform you that CUPRA contracts third parties who are responsible for processing data and who, in order to render such services, may have access to your personal information. As part of the product improvement CUPRA uses Google Analytics. CUPRA cannot preclude the possibility that the information will be accessed by Google, LLC with headquarters in the USA. Corresponding EU standard contractual clauses for the transmission of personal data to processors in third countries were concluded. You can access the EU standard contractual clauses from the following URL: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32010D0087 How long will we keep your data? CUPRA will store your personal information for the time deemed necessary in order to perform the services included in the App, and until such time as you request that your information be deleted. In this case, you will no longer be able to use the App as it is not possible to access it without a user account. Additionally, your personal information will be saved for the time deemed necessary in order to fulfil the legal obligations that apply in each specific case. What is the source of the personal information? Your personal information was provided by the Users. In other words, the responsible parties at the dealers with CUPRA Corners and for whom you are employed have been designated a CUPRA Master. What are your rights as data subject? You can exercise the following rights: -Access: you can obtain from us a confirmation as to whether your personal data are being processed and access to your personal data. -Rectification: you can obtain the rectification of inaccurate personal data concerning you. You also have the right to have incomplete personal data completed. -Erasure: you can request the deletion of your personal data when, among others, the personal data are no longer necessary for the purposes for which they were collected or otherwise processed. -Object: you can object to the processing of your personal data. We will no longer process your personal data unless it has compelling legitimate grounds for the processing or for the establishment, exercise, or defence of legal claims. •Restriction: you can request the restriction of the processing of your personal data where one of the following grounds applies: •The accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of such data. •The processing is unlawful, and you oppose the erasure of your personal data and request the restriction of their use instead. •We no longer needs your personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims. •You have objected to the processing, pending the verification whether we have legitimate grounds override yours. -Portability: you can receive the personal data that you provided us in a structured, commonly used and machine-readable format. You can also have these data transmitted to another controller. -If the processing of personal data is based on your consent: you can withdraw your consent at any time. Your consent withdrawal will not affect the lawfulness of processing based on consent before its withdrawal. You can exercise these rights by submitting a written request to the Data Controller’s address or by sending a email to us privacy@cupraofficial.es. Your request must specify the right you wish to exercise. The exercise of these rights is free of charge. Should you consider that we have not processed your personal data in accordance with applicable law, you can lodge a complaint with the relevant supervisory authority.
CONDITIONS OF USE CUPRA MASTER COMMUNITY PLATFORM
1. Introduction SEAT, S.A.U. (hereinafter, “SEAT”) is a Spanish entity domiciled on Autovía A-2, km 585, 08760, Martorell, Barcelona, assigned the tax ID number (N.I.F.) A-28049161, duly registered in the Commercial Registry of Barcelona in Volume 23662, Sheet 1, page number B-56855 and whose contact email is digital@cupraofficial.com SEAT is the owner or licence holder of the intellectual property rights, industrial property rights and any other technology, software, design, trademarks, and multimedia content associated with the app named “CUPRA Master Community Platform”(hereinafter, the “App”). The App is intended for CUPRA Dealers and Agents (hereinafter, the “Users”) who shall act through the individuals designated for that person (hereinafter, the “Designated Users”), who may share certain types of content via this App, and who may use it in general on behalf of the Users. These conditions of use (hereinafter, the “Conditions of Use”) regulate access to and use of the App by the Users and shall be supplemented with whichever other legal texts that regulate any type of function, service, application, platform or other media necessary to use the App or included as part of the App. The Conditions of Use must be explicitly accepted by the Users prior to accessing the App (as stated below) and shall be available for consultation and review at all times on the home page of the App. The Users shall ensure that the Designated Users comply with and observe that which is set out in the Conditions of Use at all times. 2. Purpose The purpose of the App is to provide its Users with a digital platform that allows them to share experiences and events related to the CUPRA brand. The App offers Users the possibility to upload and share content with other Users via the app and comment on the information and content published in the App by other Users. In addition, the Users can interact with one another by writing comments on the “wall” and, where available, by participating in community groups. The App also provides training tools and training activities and materials for Users regarding CUPRA, which may contain games, quizzes and challenges. Additionally, a third party may review the dealers’ professional social media and provide feedback maintaining a later interview. SEAT reserves the right to delete any content that does not comply with the stipulated conditions or to request that Users do so themselves with immediate effect. In particular, but not exclusively, it is expressly prohibited to share any type of legal content or anything that might be considered a violation of applicable competition law rules or third-party rights; or anything that might be contrary to morals and good customs, as well as commercially sensitive information (among others, on prices, units and commercial/sales conditions), financial information or other trade secrets or secret data etc. about Users themselves or third parties. 3. Access to the App Users must use their user account for the CUPRA Training Hub to access the App and then accept these Conditions of Use, as well as the App’s Privacy Policy. If the User does not have a user account for the CUPRA Training Hub, the User must create one by registering at www.cupratraininghub.com Once logged-in the App, the Users may complete or edit any additional data required for their App profile. Users are responsible for ensuring the veracity, accuracy and authenticity of the information provided. Accordingly, the Users agree to maintain the information contained in the User Account up to date. SEAT shall not be liable for any damage resulting from choosing an inadequate password or not protecting the password properly, which would entail a failure to comply with the Conditions of Use, nor any damages caused by third parties who have access to the User Account of the Users, irrespective of whether or not they have the authorisation of the Users in question. 4. Intellectual and Industrial Property Intellectual and industrial property rights, or rights to the App of any other type (including its software, designs, videos, multimedia content, images, photos, distinguishing signs, trademarks, etc.) are the property of SEAT and/or its licensors. SEAT and the Users are considered the owners of the intellectual and industrial property rights, or any other type of rights, as appropriate, related to the contents shared by each (including videos, multimedia content, images, photos, etc.). As such, the User is prohibited from using, reproducing, transmitting, altering, distributing or exploiting the App and/or its elements by any means other than the uses strictly necessary to utilise the services offered through the App. In this respect, SEAT grants a non-exclusive, non-sublicensable, non-transferable licence to the Users to use the App, which is subject to the rest of the terms included in these Conditions of Use, as well as any other terms of use and applicable legislation. For their part, the Users grant a non-exclusive, non-sublicensable, non-transferable licence to the other Users and to SEAT for the use of the shared content. In any event, Users must refrain from decompiling, disassembling or reverse engineering the App. In addition, Users must not under any circumstances delete, alter, elude or manipulate any protection device or security systems that might be installed in the App. Users acknowledge and accept that using the App does not imply the transfer of any intellectual or industrial property rights, nor that of any copyrights, design rights or other rights to the App; nor does it constitute an authorisation for the creation of any developments based on the App and/or its elements, except for the limited licence for use that is granted to Users under the terms stipulated here. 5. Modifications to the Conditions of Use SEAT reserves the right to modify or update these Conditions of Use at any time. Users shall be notified expressly, within a reasonable period of time, about any changes to the Conditions of Use of the App in order to provide their express consent. Users can find the latest version of these Conditions of Use in the App. SEAT reserves the right to extend, reduce or modify the services in the App at any time. In order to use the App, User must expressly accept the Conditions of Use in effect at the given time. 6. Proper Use The User agrees to not misuse the App. In particular, The User agrees not to do any of the following: - Activities that break existing laws or current Conditions of Use, contrary to morals and good customs or to the established public order, or for purposes considered illicit, prohibited or injurious to the rights and interests of SEAT or third parties. In particular, activities that violate competition laws, copyrights, names or registered trademarks, or privacy rights. - Sharing and exchanging commercially sensitive information (among others, on prices, units and commercial/sales conditions), financial information or other trade secrets or confidential data, etc. about Users themselves or third parties. All data / information are classified as for internal use only. - Using the App and its contents for resale or commercial purposes; or establishing hyperlinks to the App or any of its contents (except with the express written consent of SEAT). - Altering, copying, modifying, decompiling, disassembling, reverse engineering, licensing, leasing, selling or imitating the App or any of its contents. - Transmitting a virus or other harmful component that impairs, limits or damages the App or any connected network or that interferes with the use and enjoyment of the App by other Users. - Disclosing, extracting, reusing, forwarding or exploiting any components of the App in any way, in whole or in part, in any format or media. SEAT reserves the right to block access to certain services of the App for any User who violates the Conditions of Use, the rights of third parties or applicable legislation and, in particular, the obligations stipulated in this clause. In this context, SEAT reserves the right to delete the App or prevent the displaying of information or content shared by Users that is not appropriate for the intended purpose of the App, or that violates these Conditions of Use, the rights of third parties or applicable legislation and, in particular, the obligations stipulated in the this clause. SEAT shall retain all additional rights to which it is entitled in relation to Users, especially those concerning the initiation of criminal or legal proceedings. 7. Notification of Potential Violations SEAT respects the rights of third parties and applicable legislation. Users of the App are obligated to do the same. Accessing the App for illicit or harmful purposes that may affect SEAT or third parties directly or indirectly is strictly prohibited. Should any User detect an offensive use of the App and/or one for purposes contrary to applicable laws, they should notify SEAT immediately by sending a notification to the email address: digital@cupraofficial.com. 8. Service and Warranty Disclaimer SEAT shall make every reasonable effort to ensure the correct functioning of the App. Nevertheless, SEAT cannot guarantee the absence of interruptions in service in order to carry out repairs or maintenance tasks on the App, or the lack of coverage, equipment malfunctions, or failures in the networks required to transmit the data, which are beyond its control. SEAT shall take appropriate measures to reduce said interruptions. SEAT shall make every reasonable effort to ensure that the information contained in the App is accurate, correct and up to date. Nevertheless, said information is of an indicative nature and, as such, is solely intended to provide general information and not detailed or specific information. In this regard, such information is subject to change. 9. Liabilities Users use the App on their own and at their own risk. By accessing it, Users agree to use and ensure that the End Users use the App in accordance with the law, and shall be liable to SEAT and/or third parties in the event of any damage or harm that may occur as a result of failing to comply with said obligations. Accordingly, SEAT shall not be held liable for any damage or modification to the equipment of the Users as a result of their installing, accessing or using the App. Users are fully responsible for the information they transmit and communicate through the App. In this context, Users shall fully compensate SEAT in the event of any claims or any judicial or extrajudicial proceedings, or those of any other nature, and initiated before any authority because of the nature of said information or content. Furthermore, Users shall be liable for the use of information or content obtained through the App, regardless of whether it was SEAT or a User who shared said information on the App, and shall compensate SEAT in full as indicated above. SEAT does not control or monitor the aforementioned content in a comprehensive manner, unless ordered to do so by the competent court or an administrative decision. However, it will carry out a reviewing function, to the extent possible, reserving the right to delete the App or prevent the displaying of information or content shared by Users that is not appropriate for the purpose of the App, or that violates these Conditions of Use, the rights of third parties or applicable legislation and, in particular, the obligations stipulated in Clause 6, and for the period it deems appropriate until such time as the ownership of the material in question or the legality of the same can be determined. SEAT assumes no liability for any damages or losses caused as a result of Users having selected inadequate passwords or not having kept said passwords safe, thus violating the Conditions of Use or any other applicable terms, or for damages or losses caused by third parties to whom the Users have granted access to their User Account. SEAT assumes no liability for potential security errors that may occur or for potential damages caused to the equipment of the Users (hardware and software) and/or the files and documents saved on said equipment as a result of the presence of a virus on the equipment used by the Users to connect to the services and contents of the App, or for any Internet malfunctions, telephone faults, interferences, failures or disconnections in the operational performance of the App for reasons that cannot be attributed to SEAT. Using the services offered through the App may require the consumption of data. SEAT assumes no liability for the costs incurred by the Users as a result of communicating and sending data or connecting to the Internet. The Users can consult their telecommunication operators to obtain further information on the subject. The App may contain links to other websites and may incorporate information and/or services obtained from third parties for the purpose of facilitating User access to information provided by collaborating companies or sponsors, among others. SEAT has no control over this and assumes no liability for its content, its functioning or the transmission received by said third parties. SEAT offers Users said links and information and/or services solely for the convenience of Users, who are responsible for reading and accepting the terms of use and privacy policies published on the linked websites or applications. Furthermore, SEAT cannot control the information, content, products or services provided by third parties who have established links to the App. Therefore, SEAT assumes no liability for anything arising as a result of this, or as a result of Users using features, technology, services or platforms of third parties. To this effect, Users agree to release SEAT from any liability or payment of damages and harm caused due to violations or incidents related to the use of said features, technology, services or platforms supplied by third parties, despite being available through the App. The Portal may host advertising content or promotions, and it is the advertising companies and providers of said promotions that are solely responsible for ensuring that the material sent for inclusion on the Portal complies with any laws that may apply. SEAT assumes no liability for any errors, inaccuracies or irregularities that may be harboured by said content. In any event, to lodge any sort of claim related to the advertising content published on the Portal, please contact the following email address: digital@cupraofficial.com Generally speaking, SEAT does not control how Users utilise the App. In particular, SEAT cannot guarantee under any circumstances that Users will use the App in compliance with the law, Conditions of Use, generally accepted morals and good customs, and public order, nor that they will do so in a diligent and prudent manner. Therefore, SEAT assumes no liability for Users making use the contents in the App in a manner that could imply a violation of any standard, national or international, intellectual or industrial property rights or any other rights of third parties. 10. Data Protection SEAT shall protect the personal information of the Users and shall only use such information to the extent laid out by law. Users can find more information regarding the processing of their personal information in the Privacy Policy of the App. 11. Policy on Cookies and Similar Technologies Users should know that this App does not use cookies or any similar technologies for the purpose of storing information and recovering previously stored information. 12. Independence and Integration of Clauses The illegality, invalidity or ineffectiveness of any of the clauses in these Conditions of Use shall not affect the validity of the rest, provided the rights and obligations of SEAT or of Users, based on the Conditions of Use, are not affected significantly as a result. Any situation that would gravely harm the interests of either party, or that would impair the purpose of these Conditions of Use, shall be considered significant. Said clauses must be replaced or integrated into other clauses that, in compliance with the law, fulfil the purpose of the ones being replaced. SEAT and Users shall waive any claims for damages and harm that may be requested as a result of these circumstances. 13. Final Provisions, Applicable Legislation, Competent Judicial Courts a. These Conditions of Use are governed by Spanish common law. b. Any disputes arising as a result of using the App or contravention of these Conditions of Use shall be submitted to the competent courts of the City of Barcelona (Spain). © SEAT, S.A. 2025. Reproduction prohibited in whole or in part. All rights reserved.