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Privacy Policy

PROTECTING YOUR PRIVACY – OUR COMMITMENT

At Global Voice Group Worldwide Corporation S.A.U. (“GVG”), we value your
privacy. Regardless of whether you are our customer, a visitor to the GVG website, or
someone we deal with in our ordinary course of business, protecting your privacy is important
to us and is a responsibility that we take very seriously.

In this Privacy Policy, we describe how we collect, use, and disclose information that we
obtain and what your rights are in this regard. For the purposes of this Privacy Policy, any
reference to “Services” is a reference to all the products and services offered by GVG,
whether available online or offline, and any reference to “Site” is a reference to any of the
GVG website.

By using our Site or our Services, or otherwise providing information to us, you agree that
your personal information will be handled as described in this Privacy Policy. You also agree
to the terms for accessing and correcting data as described in this Privacy Policy. Your use of
our Site or Services, and any dispute over privacy, is subject to this Privacy Policy and our
Terms of Service (which are incorporated by reference into this Privacy Policy). Depending
upon your interactions with GVG, other terms may also be applicable to you.

THE INFORMATION WE COLLECT

Information We Collect Directly From You. When you communicate or do business with
us, we collect information from you, and this may include personal information. For example,
we collect information from you when you sign up for our Services, create an online account
with us, request information, participate in a contest or survey, or otherwise contact us. The
type of information that we collect depends on your interaction with us, but may include,
where permitted by applicable law, the following: your name, company name, email address
(business or personal), mailing/billing address (business or residential), telephone number
(business or personal), and any other information that you choose to provide.

Information We Collect Automatically. We automatically collect the following information
about your use of our Site or online Services through cookies, web beacons, log files and other
technologies: your domain name, your browser type and operating system, web pages you
view, links you click, your IP address, the length of time you visit our Site or use our Services,
your activities on our Site or Services (including your movement through our Site), and the
referring URL or the webpage that led you to our Site. Please see the section “Our Use of
Cookies and other Tracking Mechanisms” below for more information.

We may use the information we collect from you in aggregated form or we may associate it
with your username and other personal information that we collect about you. We may also
combine information collected about you on one of our Site with information collected
through one or more of our other Site or through your use of our Services for the same
purposes as we would use such information in non-combined form. We explain how we use
and disclose the information we collect about you below.

Information About Your Use Of Our Services.

Where permitted by applicable law, we also collect information about your use of our
telecommunications and services, amongst other data.

Information We Collect About You From Third Parties. We also may collect information
about you, such as name, contact, or demographic information from third party sources, such
as research service providers. Where permitted by applicable law, we may combine this data
with information that we already maintain about you. We will use this information as
described in this Privacy Policy.

HOW WE USE THE INFORMATION WE COLLECT

We use the information that we gather about you for the following purposes:

– To provide our Services to you, to communicate with you about your use of our Services.

– For the purpose for which you specifically provided the information to us, including, to
respond to your inquiries, to provide any information that you request and for providing
service.

– Where permitted by applicable law, to deliver customized content to you, to offer location
customization, personalized help and instructions, and to otherwise personalize your
experiences while using our Site or our Services.

– For marketing and promotional purposes, for example, where permitted by applicable law,
we may use your information, such as your email address, phone number, or mailing
address to contact you with newsletters, special offers and promotions, or to otherwise
contact you about products or information we think may interest you including voice, data,
and internet communications products and services, as well as to track the success of our
marketing and advertising campaigns.

– As permitted by applicable law, to assist us in advertising our products and services in
various mediums including, without limitation, sending promotional emails, advertising our
services on third party Site and social media platforms, direct mail, and by telemarketing.

– To better understand how users access and use our Site and Services, both on an aggregated
and individualized basis, to administer, monitor, and improve our Site and Services, for our
internal purposes, and for other research and analytical purposes.

– To protect our customers, employees or property — for instance, to investigate fraud,
harassment or other types of unlawful activities involving GVG or other partners that we do
business with, and to enforce this Privacy Policy.

HOW WE SHARE THE INFORMATION WE COLLECT

We may share your information as follows:

– Affiliates. We may disclose the information we collect from you to our subsidiaries. Our
subsidiaries may use your information for the purposes indicated in this document,
including, to market their products and services to you, to the extent permitted by law.

– Marketing Partners. We may jointly offer a product or service, such as data and internet
communications products and services, with third parties who are system integrators,
resellers, solution partners, network partners and affinity organizations. If we do so, we may
share your information, such as your email address, phone number, or mailing address, with
these third parties to assist in providing and marketing that product or service to you, as
well as to enable the third parties to market their own products and services to you. We also
may share your information with companies that are system integrators, resellers, solution
partners, partners and affinity organizations, and whom we believe might offer products and
services of interest to you; these companies may market to you, and may share information
with you about their products and services.

– Service Providers. We may disclose the information we collect from you to third party
vendors, service providers, contractors or agents who perform functions on our behalf. We
take steps to ensure that third party contracts contain appropriate data protection and security
language.

– We may also share your information in the following circumstances and with the following
persons/entities:

– Other Purposes for Which We May Seek Your Consent: From time to time, we may
seek your consent to use your information for a purpose not described in this Privacy
Policy. We may also share your personal information with third parties under other
circumstances where we have your consent. For example, we may offer you the opportunity
to participate in a survey or promotion; where applicable, your information will be used and
shared as described in the instructions/rules to that survey and/or promotion.

– Business Transfers. If we are acquired by or merge with another company, or if
substantially all of our assets are transferred to another company (which may include as part
of bankruptcy proceedings), we may transfer the information we have collected from you to
the other company.

– In Response to Legal Process. We may disclose the information we collect from you in
order to comply with applicable law, judicial proceedings, a court order, or other legal
process, such as in response to a court order or a subpoena.

– To Protect Us and Others. We may disclose the information we collect from you where
we believe it is necessary to investigate, prevent or take action regarding illegal activities,
suspected fraud, situations involving potential threats to the safety of any person, violations
of our Terms of Service or this Privacy Policy, or as evidence in litigation in which we are
involved.

– Aggregate and De-Identified Information. We may share aggregate or de-identified
information about users with third parties for marketing, advertising, research or similar purposes.

JOB APPLICANTS

If you submit your resume or otherwise apply for a job with GVG, we use and disclose the
information you submit for employment consideration only unless we otherwise obtain
consent from you.

THIRD-PARTY AD NETWORKS

We may use third parties such as network advertisers to display advertisements about GVG on
third party website. Network advertisers display advertisements on third-party Site, based on
your visits to our Site as well as other website. This enables us and these third parties to target
advertisements by displaying ads for products and services in which you might be interested.
Third party ad network providers, advertisers, sponsors and/or traffic measurement services
may use cookies, JavaScript, web beacons (including clear GIFs), Flash LSOs and other
technologies to measure the effectiveness of their ads, to personalize advertising content to
you, and to track your movements on our Site and on other third party Site. These third party
cookies and other technologies are governed by each third party’s specific privacy Privacy
Policy, and not this one. We may provide these third-party advertisers with de-identified
information about your usage of our Site and our Services, as well as aggregate information

about visitors to our Site and users of our Services; however, we do not share your personal
information with these third parties.

You may opt-out of many third-party ad networks, including those operated by members of
the Network Advertising Initiative (“NAI”), the Digital Advertising Alliance (“DAA”), or, in
Europe, the European Interaction Digital Advertising Alliance (“EIDAA”).

COMMUNICATIONS AND MARKETING

Where permitted by applicable law, we may send periodic promotional or informational
emails to you. You may opt-out of such communications by following the opt-out instructions
contained in the e-mail or filling out the following form with your request:…….. GVG….
Please note that it may take up to 10 business days for us to process opt-out requests. If you
opt-out of receiving emails about recommendations or other information we think may interest
you, we may still send you e-mails about your account or any Services you have requested or
received from us.

USER GENERATED CONTENT

We may invite you to post content on our Site, including your comments, pictures, and any
other information that you would like to be available on our Site. If you post content to our
Site, the information that you post will be available to other visitors to our Site. If you post
your own content on our Site or Services, your posting may become public and we cannot
prevent such information from being used in a manner that may violate this Privacy Policy,
the law, or your personal privacy.

THIRD-PARTY LINKS

Our Site and our online Services may contain links to third-party website. Any access to and
use of such linked website is not governed by this Privacy Policy, but instead is governed by
the privacy policies of those third party website. We are not responsible for the information
practices of such third party website.

SECURITY

To prevent unauthorized access, maintain data accuracy and ensure the correct use of
information, we have put in place physical, electronic, and managerial procedures to safeguard
and secure the information we collect through our Site and the provision of our Services.
Despite our best efforts, you will appreciate that no data security measures can guarantee
100% security.

You should therefore take steps to protect against unauthorized access to your password,
phone and computer by, among other things, signing off after using a shared computer,

choosing a robust password that nobody else knows or can easily guess, and keeping your log-
in and password private. We are not responsible for any lost, stolen or compromised

passwords, or for any activity on your account via unauthorized password activity.

HOW TO ACCESS, CORRECT, AMEND OR DELETE YOUR
INFORMATION

To access, correct, amend, or delete your account information and other personal information
that the Company may be storing about you (for example, your name, or address,), you may
send an email to the following address: ……@GVG.io . To protect your privacy and security,
we will also take reasonable steps to verify your identity.

TRANSFER OF PERSONAL INFORMATION BETWEEN COUNTRIES

GVG may transfer personal information across national borders. Your personal information
may be transferred to and processed by other GVG entities and third parties for the following
purposes, where permitted by local law: to fulfill our contractual obligations to you, to manage
your account, for business operations, to monitor compliance with our policies and
procedures, to improve our products and services, to monitor compliance with law, and for
other purposes for which we may notify you from time to time.

Any such transfer will occur either on the basis of any consent you have provided or on the
basis of the Spanish law and/ or EU Commission-approved model clauses (which seek to
ensure an equivalent level of protection for your personal information as provided by your
country of residence). As a result of such transfers, your information may be subject to access
by law enforcement and Government entities in countries other than your country of residence,
including courts and tribunals in accordance with laws applicable in those jurisdictions.

GVG takes steps to ensure that your personal information is protected when transferred to and
processed by these GVG and other entities, and to ensure that such processing complies with
applicable laws. If you have questions about the third parties to whom we have transferred
your information, you may email us at ……@GVG.io .

OUR COMMITMENT TO GDPR

GVG currently processes and manages personal data in accordance with applicable privacy
Spanish laws, specifically, in accordance with the EU Data Protection Directive, which is
regarded as one of the highest and strictest in the world. GVG’ Privacy Policy, further
explains in detail its practices and processes with respect to handling of any Personal Data it
receives from its customers.

GDPR is an important step forward for clarifying and enabling individual privacy rights. GVG
is committed to GDPR compliance across its products and services and provide GDPR related
assurances in its contractual commitments then.

CHANGES TO THIS PRIVACY POLICY

This Privacy Policy is subject to change, and any changes to this Privacy Policy will be posted
on our Site. All information submitted through the Site to GVG is subject to the terms and
conditions of this Privacy Policy, as amended.

HOW TO CONTACT US

You may email us at the following address – please describe the nature of the problem or issue
you wish to report in detail, or you may write to us at the following address:

legal@GVG.io

Global Voice Group Worldwide Corporation S.A.U.
Calle de Principe de Vergara numero15, bajo Madrid Spain