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April 4th, 2023

The EDP Renováveis Group is committed to guaranteeing and respecting the privacy of its shareholders, as data subjects, in accordance with the regulations on personal data protection. Therefore, through this Privacy Policy, you are informed of the conditions under which your personal data will be processed in the context of the General Meeting to be held by this entity. 

In addition, the data subject must read this information carefully, as it has been written in clear and simple language to allow it to be easily understood. Furthermore, at the time of providing his/her personal data, the data subject must ensure that these data are truthful, accurate and updated, exempting EDP Renováveis from any damage, direct or indirect, that could be caused as a consequence should this not be the case. 

In those cases in which representation or remote voting includes personal data referring to individuals other than the holder, the data subject must inform them of the points contained in this Privacy Policy exempting the Data Controller from any responsibility in this regard. 

1.    Identification of the data controller 

In accordance with Regulation (EU) 2016/679 (General Data Protection Regulation) and Organic Law 3/2018 of 5 December on the protection of personal data, data subjects are informed that their personal data will be processed by EDP RENOVÁVEIS, S.A. ("Data Controller" or the "Company" indistinctly) whose identification data are the following: 

-    Spanish Tax ID (NIF): A74219304 

-    Registered office: Plaza de la Gesta nº 2, 33007 Oviedo, España. 

-    Data Protection Officer contact: dataprotection@edpr.com 

2.    Purpose of the processing of your personal data 

The Data Controller will process the data subject's data, in a clear and transparent way, for the following legal, specific and sole purposes: 

i)    To manage the exercise or delegation of his or her right to attend and vote at the General Shareholders' Meeting, whether data are obtained by the shareholder, or are provided for this purpose by the banks and securities brokers and dealers in which these shareholders have their shares deposited or held (in which case their identification details, contact details and details relating to their shareholding situation will be processed);  

ii)    To draw up a list of participants in order to properly manage the various processes arising from their status as shareholders at the General Meeting. 

iii)    To manage the proper functioning and development of the existing shareholder relationship with the data subject within the framework of the aforementioned Meeting.  

iv) Manage your access to and participation in the General Shareholders' Meeting electronically, when you choose to attend the meeting by this means. Your identification, contact and shareholder data will be processed in order to generate your access user name through the Platform set up for this purpose and enable you to connect to the meeting.  

v) Broadcast live and record the General Meeting by telematic means, in order to enable all interested parties to attend, guarantee and validate their identity and, where appropriate, exercise any rights they may have to assert their claims, in accordance with the Company's Articles of Association. 

vi) Manage its registration and supervise the operation of the Shareholders' Forum set up in accordance with the terms set out in the Forum's Operating Regulations.    

3.    Legitimate grounds for the processing of your personal data 

The grounds that legitimise the processing of the data subject's personal data for the purposes described above are, mainly, the execution of a contractual relationship between the data subject and the Data Controller, which justifies said processing, together with the fulfilment of legal obligations to which the Data Controller is subject, in accordance with the applicable legislation.  

Specifically, for the processing of personal data consisting of the retransmission and recording of the General Meeting, the legitimate basis is the execution of the contractual relationship of a shareholder nature with the data subject, pursuant to the provisions of the Company's Articles of Association and article 182 of the Capital Companies Act. 

The processing of personal data for these purposes is mandatory, in order to comply with the contractual and legal obligations to which the Data Controller is subject. If this processing is not carried out, these obligations cannot be met. 

Likewise, if you choose to attend the General Meeting by telematic means, the personal data necessary to generate your user name and manage your access to the platform will be processed with your express consent, freely expressed when requesting the creation of the access user name through the authorized means. 

Likewise, if you decide to participate in the Shareholders' Forum, your data will be processed in order to manage your registration and monitor the operation of the forum. By registering and actively participating in the forum, you consent to the processing of your personal data necessary for this purpose. 

4.    Time limit for the storage of your personal data 

The data subject's personal data will be kept for a period of 6 years, until the deadline for any possible actions deriving from them expires, in accordance with the applicable regulations. 

5.    The recipient of your personal data 

The data of the data subjects may be communicated within the context of the General Meeting to notaries, for the purpose of drawing up notarial instruments, or be accessible to the public to the extent that it is contained in the documentation available for consultation or stated at the General Meeting, or to third parties in the exercise of the right to information provided for by law. 

6.    International data transfers 

In general, the data subject's personal data will not be transferred internationally to third countries outside the European Economic Area. 

Notwithstanding the foregoing, you are hereby informed that some providers necessary for the conduct of the General Meeting may carry out international transfers of your data. In particular, if you choose to attend and participate telematically in the General Meeting, the provider of the platform, provided for this purpose, foresees the possibility that your data may be processed outside the European Economic Area. 

In the case of transfers to countries that are not considered to have an adequate level of protection according to the applicable Data Protection Legislation and/or the competent supervisory authority, EDPR has implemented appropriate and adequate safeguards to protect the personal data of data subjects and to ensure an adequate level of security. Accordingly, personal data of data subjects will be transferred in accordance with the requirements and obligations established by the applicable data protection legislation. In these cases, EDPR guarantees to have subscribed with the recipients, collaborators and/or suppliers accessing the personal data, the corresponding Contractual Clauses and determined the additional guarantees, where necessary, for the best protection of their personal data. 

7.    Rights of the data subject 

The data subject has the right to: 

-    Revoke, where appropriate, the consent granted, notwithstanding the legality of the processing carried out until that time. 

-    Access his or her personal data. 

-    Rectify inaccurate or incomplete data. 

-    Request the deletion of his or her data when, among other reasons, the data are no longer necessary for the purposes for which they were collected. 

-    Oppose the processing of his or her data by the Data Controller, in accordance with regulations. 

-    Request from the Data Controller the limitation of data processing when any of the conditions provided for in the applicable regulations are fulfilled. 

-    Request the portability of his or her personal data. 

In this regard, the data subject is informed that his or her personal data will not be subject to automated individual decision-making (including profiling). 

For the purposes of exercising the above rights, the data subject may contact, through a written communication at the Departament of Compliance - C/ Serrano Galvache, nº 56, Edificio Olmo, 6ª planta, 28033 Madrid, or by e-mail dataprotection@edpr.com.  

Lastly, when the data subject believes that the Data Controller has infringed the rights that are recognised by the applicable regulations on data protection, he or she will be able to file a complaint before the Spanish Data Protection Agency through its physical address C/ Jorge Juan, 6. 28001 - Madrid or the web page https://www.aepd.es/. 

8.    Technical and organisational measures 

The Data Controller will process the personal data of the data subject, at all times, in an absolutely confidential manner while respecting the mandatory duty of secrecy with regard to them, in accordance with the provisions of the applicable regulations. Thereby adopting for this purpose the necessary technical and organisational measures that guarantee the security of the personal data and avoid their unauthorised alteration, loss, processing or access, taking into account the state of the art, the nature of the data stored and the risks to which they are exposed. 

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