APP PRIVACY POLICY

Last updated: 17/09/2026

This document is an English translation provided for information purposes only; in the event of any discrepancy, the Spanish version shall prevail.

This Privacy Policy sets out the processing that SLALOM UGC MARKETPLACE SL will carry out on the personal data collected through the UGC SLALOM mobile application. Hereinafter, the APP may be referred to as the “Platform”.

The use of the services of the UGC SLALOM application is subject to the Terms and Conditions of Use described below. By using these services, you understand, acknowledge and accept this Privacy Policy, as well as the Terms and Conditions of Use.

It is advisable to read the Privacy Policy, as well as the Terms and Conditions of Use, carefully. Should you have any questions or require any clarification, you may contact SLALOM UGC MARKETPLACE SL at the following email address PIA@UGCSLALOM.COM or in writing at the address PLAZA PAU VILA, OTR 1, 08039 BARCELONA (BARCELONA).

This Privacy Policy and the Terms and Conditions of Use shall apply to the access to and use of UGC SLALOM, and/or to any function, content, tools and services accessible in connection with the application. UGC SLALOM shall not be liable if the user agrees content outside the APP. UGC SLALOM reserves the right to change or modify any part of the Privacy Policy and/or the Terms and Conditions of Use or any service policy. The User of UGC SLALOM will be informed in advance of any changes affecting them, in relation to this Privacy Policy and/or the Terms and Conditions of Use and/or the functionality of UGC SLALOM itself. Any change or modification shall take effect once published at https://ugcslalom.com/ and/or in the UGC SLALOM application.

Notified modifications shall be deemed accepted if the User uses the service. Consequently, it is the User’s obligation to review these conditions and other applicable policies frequently in order to be aware of the Privacy Policy and the Terms and Conditions of Use that apply to the service provided. Non-acceptance of the modifications entails the loss of the right to use the UGC SLALOM application, and the User must therefore stop using the Service.

1. GENERAL INFORMATION

IDENTIFICATION OF THE DATA CONTROLLER

In accordance with the requirements of Article 10 of Spanish Law 34/2002, of 11 July, on Information Society Services and Electronic Commerce (Ley 34/2002, de 11 de julio, de Servicios de la Sociedad de la Información y de Comercio Electrónico, LSSI-CE), SLALOM UGC MARKETPLACE SL provides the following information:

• Company name: SLALOM UGC MARKETPLACE SL,
• Tax ID (NIF): B75869198
• Registered office: PLAZA PAU VILA, OTR 1, 08039 BARCELONA (BARCELONA)
• Telephone: 676454069
• Email: PIA@UGCSLALOM.COM

Website: https://ugcslalom.com/, which is directly linked to the App.

• Registered in the Commercial Registry of Barcelona (Registro Mercantil de Barcelona):
  • Volume (Tomo): 130988
  • Sheet (Hoja): B630528
  • Page (Folio): 1
  • Entry (Inscripción): 1st
  • Irus: 1000444661056

NAME OF THE APP

UGC SLALOM (hereinafter, the APP)

PURPOSE OF UGC SLALOM

UGC SLALOM is an application intended for content creators (natural persons) and companies: brands and agencies.

CATEGORY OF UGC SLALOM

The application could be considered to fall within the category:

Commerce

INTENDED USERS

UGC SLALOM is intended for the following users:

• UGC creators, brands and agencies

LANGUAGES OF UGC SLALOM

UGC SLALOM informs that it is available in the following languages:

• Spanish
• English
• German
• French
• Italian
• Portuguese

This documentation may be available in different languages. In the event of any discrepancy, contradiction or difference in interpretation between the different language versions, the version drafted in Spanish shall prevail.

2. DATA PROTECTION POLICY

Pursuant to the provisions of the Directive on privacy and electronic communications (Directive 2002/58/EC as amended by Directive 2009/136/EC), terminals: “The terminal equipment of Users of electronic communications networks, as well as any information stored on such equipment, form part of the private sphere of the Users requiring protection in accordance with the European Convention for the Protection of Human Rights and Fundamental Freedoms”.

In accordance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and Spanish Organic Law 3/2018, of 5 December, on the Protection of Personal Data and Guarantee of Digital Rights (Ley Orgánica 3/2018, de 5 de diciembre, de Protección de Datos Personales y garantía de los derechos digitales), UGC SLALOM informs the User, in relation to the platforms, that the information that may be collected on the websites will be incorporated into the processing systems for which SLALOM UGC MARKETPLACE SL is responsible, for the purposes of managing and maintaining the relationship between the User and the websites, as well as for information, statistical and marketing tasks concerning the services and the activities related to them.

Legal bases for processing

SLALOM UGC MARKETPLACE SL informs that the legal bases for the processing of personal data that we carry out are the following:

• The legal basis for managing the relationship between the APP and its users is the performance of a contract to which the data subject is party (Art. 6.1.b GDPR). In the case of data revealing ethnic or racial origin, the enabling condition is the explicit consent of the data subject provided for in Article 9.2.a) GDPR, obtained by means of a specific, informed and unambiguous indication. Providing this information is entirely voluntary and refusing to do so will not prevent registration, access to or use of the platform, or participation in campaigns, except in those cases in which the campaign itself expressly requires certain representative profiles.
• The legal basis for managing regulatory compliance is compliance with a legal obligation (Art. 6.1.c GDPR).
• The legal basis for commercial actions is, as a general rule, the consent of the data subject (Art. 6.1.a GDPR) and, in the case of sending commercial communications concerning products or services similar to those initially contracted by the customer, legitimate interest (6.1.f GDPR).
• The legal basis for managing contests and promotions is the consent of the data subject (Art. 6.1.a GDPR),
• The legal basis for managing payments is the performance of a contract to which the data subject is party (Art. 6.1.b GDPR) and compliance with a legal obligation (Art. 6.1.c GDPR), owing to the obligations arising from tax and accounting regulations.
• The legal basis for profiling is the performance of a contract to which the data subject is a party (Art. 6.1.b GDPR).
• The legal basis for preventing blocked users from registering again is the legitimate interest of the controller in the security of the platform (Art. 6.1.f GDPR).
• The legal basis for the internal app statistics is the legitimate interest of the controller in maintaining and improving the service (Art. 6.1.f GDPR).

SLALOM UGC MARKETPLACE SL informs that the data will be kept for as long as the consent given by the User remains in force, except in those cases where there is a legal obligation to retain them, and for as long as the legal and/or contractual relationship lasts.

Rights of data subjects

SLALOM UGC MARKETPLACE SL informs Users that they may exercise the rights of access, rectification, restriction, erasure, portability and objection to the processing of their personal data before the Data Controller, as well as the right to withdraw the consent given.

• Right of Access: This is the user’s right to obtain information about their specific personal data and about the processing that has been or is being carried out, as well as the available information on the origin of such data and the communications made or planned of such data.
• Right to Rectification: This is the data subject’s right to have data that prove to be inaccurate or incomplete modified. It may only be fulfilled in relation to information that is under the control of the APP, for example, deleting comments published in the application itself, images or web content containing the user’s personal data.
• Right to Restriction of processing: This is the right to have the purposes of processing originally envisaged by the data controller restricted.
• Right to Erasure: This is the right to have the user’s personal data erased, except as provided for in the GDPR itself or in other applicable regulations that make their retention mandatory, in due time and form.
• Right to Portability: The right to receive the personal data that the user has provided, in a structured, commonly used and machine-readable format, and to transmit them to another controller.
• Right to Object: This is the user’s right to have their personal data not processed, or to have the processing of their data by the APP stopped.

In order to exercise any of the rights described above, you must meet the following requirements:

• Submission of a written request to the address PLAZA PAU VILA, OTR 1, 08039 BARCELONA (BARCELONA) (for the attention of SLALOM UGC MARKETPLACE SL) or by email to PIA@UGCSLALOM.COM
• The written request sent by the holder of the personal data (data subject) requesting the exercise of rights must take the following into account:
  • The data subject must provide reliable identification and, should there be any doubt as to the identity of the applicant, they will be asked to rectify the request (e.g. by requesting further information, such as the national identity card (DNI) number, the DNI document, the email address they provided, etc.)
  • The request may be made by a legal or voluntary representative, provided that the representative is duly identified and authorised by the data holder (by means of an express authorisation from the holder to exercise the strictly personal rights regulated in the personal data protection legislation).
  • Statement specifying the request. (Exercise in which the information to be accessed is requested). If no reference is made to a specific file, all the information held containing their personal data will be provided. If information from a specific file is requested, only the information from that file will be provided. Information relating to a third party may never be provided. If the request is made by telephone, the applicant will be told to make it in writing and will be informed of how to do so and of the address to which it must be sent. Information will never be given by telephone.
  • Postal or email address for notification purposes.
  • Documents supporting the request made.

Finally, we inform you that you have the right to lodge a complaint with the Spanish Data Protection Agency (Agencia Española de Protección de Datos) if you become aware of or consider that a fact may constitute a breach of the applicable data protection legislation.

SLALOM UGC MARKETPLACE SL undertakes to adopt the necessary technical and organisational measures, in accordance with the level of risk accompanying the processing carried out and indicated in the terms and conditions of use section, so as to guarantee their integrity, confidentiality and availability.

a) Accuracy and currency of the data

UGC SLALOM informs users that the Platform may contain links to other websites unrelated to UGC SLALOM, and therefore it shall not be liable for the processing of personal data that the User provides on those websites. Consequently, we recommend that you review the privacy policies of such sites.

Likewise, UGC SLALOM informs that, if the User enters data in the forms of third-party websites, those third parties shall be the controllers of the personal data, and they shall be the ones who must adopt the technical measures described in the section of these Terms and Conditions of Use.

b) What Processing We Carry Out

PROCESSING CARRIED OUT BY UGC SLALOM

Management of APP users

• Purpose: Management of the data of users who use the platform
• Retention period: For as long as the contractual relationship is maintained and subsequently for the periods necessary to address any possible legal liabilities.
• Legal basis: Performance of a contract to which the data subject is party.
• Types of Data: Merely identifying data. Special category data (ethnic or racial origin, only where the user decides to provide this information voluntarily).
• Purpose of the special category data: to enable the suitability and visibility of the creator’s profile in campaigns that require certain representative profiles or specific physical characteristics requested by brands, avoiding in all cases discriminatory decisions or the exclusion of the user from access to the platform or its functionalities.

Management of regulatory compliance

• Purpose: Management and processing of the obligations and duties arising from compliance with the regulations to which the entity is subject
• Retention period: retention of copies of the documents until the limitation period for actions to claim any possible liability has expired
• Legal basis: Compliance with a legal obligation.
• Types of Data: Merely identifying data
• Disclosures: your data will be disclosed, where necessary, to public bodies and/or authorities with competence in the matter for the purpose of complying with the obligations established in the applicable regulations. Furthermore, we inform you that the legal basis for the disclosure is compliance with the obligations established in the applicable regulations

Commercial actions

• Purpose: Collection, recording and processing of data for advertising and commercial prospecting purposes.
• Retention period: for as long as the consent given remains in force.
• Legal basis: The consent of the data subject. And legitimate interest in those cases of sending commercial communications concerning products or services similar to those initially contracted by the customer.
• Types of Data: Merely identifying data

Management of contests and promotions

• Purpose: Collection, recording and processing of data for the purpose of running contests, prizes and promotions.
• Retention period: your data will be deleted once the legal obligations arising from the management of the activity have been fulfilled.
• Legal basis: The consent of the data subject.
• Types of Data: Merely identifying data
• Disclosures: your data may be disclosed, where necessary, to companies that sponsor the contests, prizes and/or promotions.

Management of payments

• Purpose: Administrative management, invoicing, accounting and legal obligations.
• Retention period: 4 years for compliance with tax obligations; 6 years for compliance with accounting and commercial obligations; 10 years where specific regulations on the prevention of and fight against fraud, or any other regulations establishing extended document retention periods, apply; and, in any event, for the time necessary to address any legal liabilities that may arise from the processing.
• Legal basis: Performance of a contract to which the data subject is party.
• Types of Data: Merely identifying data
• Disclosures: your data will be disclosed, where necessary, to the Tax Agency (Agencia Tributaria), Banks, Savings Banks and public bodies and/or authorities with competence in the matter for the purpose of complying with the tax obligations established in the applicable regulations. Furthermore, we inform you that the legal basis for the disclosure is compliance with the obligations established in the applicable regulations

Profiling of users

• Purpose: Management, recording and processing of users’ data, for the purpose of being located among the creators registered for an offer, assessing whether they fit the campaigns, viewing offers relevant to their profile and registering for them, and measuring the improved product.
• Retention period: The data will be kept for as long as the user keeps their account on the platform active and, once cancelled, for the periods necessary to address any possible legal liabilities arising from the contractual relationship.
• Legal basis: Performance of a contract to which the data subject is party.
• Types of Data: Identifying data, location, gender, physical characteristics, interests, personal characteristics.
• Logic applied: The following logic will be applied for profiling: The system cross-references the data of creators and brands by means of a scoring algorithm in order to show relevant offers and match the most suitable profiles for each campaign. At the same time, it analyses the use of the platform in aggregate form in order to correct errors and optimise the product. This may have the following consequences: that the creator appears in a brand’s search.

Management of blocked users

• Purpose: to prevent a user who has been blocked for breaching the Terms and Conditions from registering again. Only an encoded copy of their email is stored, which does not allow it to be read.
• Retention period: for as long as the block lasts. It is then deleted automatically.
• Legal basis: legitimate interest of the controller in the security of the platform (Art. 6.1.f GDPR).

Internal app statistics

• Purpose: recording of the platform, the app version and the date of last use, to ensure the compatibility and proper functioning of the app and to produce aggregated internal statistics. This data is not disclosed to third parties.
• Retention period: only the latest value is kept while the account is active. It is deleted or anonymised when the account is cancelled.
• Legal basis: legitimate interest of the controller in maintaining and improving the service (Art. 6.1.f GDPR).

3. PRIVACY POLICY SECURITY

SLALOM UGC MARKETPLACE SL undertakes to comply with the Terms and Conditions of Use and with the Privacy Policy in relation to the APP and the Services, in compliance with the provisions of the following sections:

a) Geolocation

UGC SLALOM requires access to the device’s geolocation, and therefore you must use the operating system’s location services. This access is considered a collection of personal data, and therefore geolocation data must be transmitted to the APP.

Prior to installation, as well as once installed, it will inform you about the use of this system, and you must expressly accept or reject it.

In any case, the User may at any time, simply and effectively, revoke the processing that the APP carries out by using the device’s location, thereby preventing the APP from accessing the processing of location data.

In any event, uninstalling the APP will entail not only the uninstallation of the APP, but also the withdrawal of the use of the device’s location for the use of the APP.

The APP may only access geolocation data while the User is using the application, and therefore this system will not be activated continuously. Should the continuous use of location data be necessary, you would be informed in advance and precisely, and your express consent would be requested separately. For more information on how to disable this function, you may consult the following links: iOS and Android. Disabling this functionality may affect the optimal functionality of the APP.

b) Applications used by UGC SLALOM

Device Permissions

Most mobile platforms (iOS, Android, etc.) define certain types of device data that the APP cannot access without your consent. These platforms have different authorisation systems to obtain your consent. The iOS platform will alert you the first time the APP wishes to obtain permission to access certain types of data and will allow you to grant, or not grant, your consent to that request. Android devices will notify you of the permissions that the APP requires before you use it for the first time. Your use of it will constitute your consent.

UGC SLALOM may use the functions of the applications available on the device itself and consequently access the data stored. In any case, the APP will inform you about the use of such applications and will request your consent, informing you beforehand in a clear and complete manner, and offering the User the possibility of expressing their wish to accept or reject the use of specific data that the APP requires for its installation.

The installation and use of UGC SLALOM will require the use of applications available on the device itself:

DEVICE PERMISSIONS

SLALOM UGC MARKETPLACE SL informs the user that the non-acceptance by the APP of the different applications on their mobile device may cause the APP not to work in its entirety and that there may be sections that are not enabled for the User. If you have any questions about the Privacy Policy, you may contact us at this email address: PIA@UGCSLALOM.COM

c) Permitted Uses and Restrictions

Users resident or domiciled in other countries of the European Union or outside the European Union must ensure that access to and use of the Application and/or its content is permitted under their own legislation. In any case, access to and use of the Application by a User who does not meet the requirement of residence in Spain shall be deemed to be carried out under their sole responsibility, releasing SLALOM UGC MARKETPLACE SL from any liability.

d) Minors

Although data protection regulations allow persons over the age of 14 to give consent to the processing of their personal data themselves, UGC SLALOM has decided to restrict access to and registration on the Platform to users over the age of 16, in view of the characteristics of the services offered.

Therefore, users who register must be at least 16 years of age and guarantee that the information provided is accurate and truthful.

UGC SLALOM may verify compliance with this requirement and take the appropriate measures, including the suspension or deletion of the account, where it has reasonable indications that the user does not meet the minimum age required to use the Platform.

e) Push notifications

This APP may send push notifications to the User in order to achieve the objectives described in this Privacy Policy and Terms and Conditions of Use.

In most cases, Users can disable the receipt of push notifications by going to their device settings, such as the notification settings for mobile phones, and then changing those settings for this Application, or for some or all of the applications on that particular device.

Users should be aware that disabling push notifications may adversely affect the usefulness of this Application.