Privacy policy

I. DATA CONTROLLER

Where the processing of your personal data relates to a supply point, the data controller will be the gas distribution company that owns the network to which your supply point is connected. You can see which distribution company corresponds to your geographical area here. These are their contact details:

COMPANY	NIF	REGISTERED ADDRESS
NEDGIA, S.A.	A66560152	Avda. América nº 38, 28028 Madrid
NEDGIA RIOJA, S.A.	A26037861	Avda. Jorge Vigón nº 51, 26003 Logroño
NEDGIA CASTILLA Y LEON, S.A.	A47068127	C/ Estación nº 4, 47004 Valladolid
NEDGIA CASTILLA-LA MANCHA, S.A.	A79238663	C/ Jarama nº 132, Polígono Industrial Santa María de Benquerencia, 45005 Toledo
NEDGIA GALICIA, S.A.	A15383284	C/ Lisboa, Area Central 31, 15707 Santiago de Compostela
NEDGIA ANDALUCIA, S.A.	A41225889	Polígono Industrial Pineda, Parcela 4, s/n, 41012 Seville
NEDGIA CEGAS, S.A.	A08009722	Avda. Cardenal Benlloch nº 67, 46021 Valencia
NEDGIA NAVARRA, S.A	A31073232	Avda. Guipuzcoa nº 40, 31014 Pamplona
NEDGIA CATALUNYA S.A.	A63485890	Plaza del Gas nº 2, 08003 Barcelona
NEDGIA MADRID, S.A.	A66036625	Avda. América nº 38, 28028 Madrid
NEDGIA ARAGON, S.A,	A66560145	C/ Adelfa nº 28, 50171 La Puebla de Alfiden, Zaragoza
NEDGIA BALEARS, S.A.	A66658816	C/ Es Cos de Gracia nº 19, 07702 Mahón, Menorca, Balearic Islands

For all other processing operations not related to a supply point, Nedgia, S.A., with registered office at Avenida de América nº 38, 28028 Madrid, and with tax identification number (NIF) A-66560152, is the data controller responsible for processing your personal data.
However, Section III specifies the company responsible for each type of processing.
This Privacy Policy will hereinafter refer to its respective data controller as ‘Nedgia’.

II. THE PERSONAL DATA WE PROCESS

II.1. Origin of the personal data we process

The personal data processed by Nedgia may come from the following sources:

Data provided by you (e.g. name and surname/s, DNI or equivalent ID document, telephone number, email address, etc.).
Data provided by the gas supply companies in compliance with the information supply obligations established in RD 1434/2002, of 27 December, which regulates the activities of transport, distribution, marketing, supply and authorisation procedures for natural gas installations, as well as in any other complementary regulations of the gas sector.
Data from third parties, in the public or private sector, public information or public access sources (e.g. information from public records, the land registry, newspapers and official bulletins, telephone directories, lists of individuals belonging to professional associations, social media, real estate portals, etc.).

II.2. Categories of personal data we process

Nedgia may process personal data of different types, depending on the purpose for which it is to be used:

Identification data and contact details, such as name and surnames, DNI, Passport or NIE, email address, postal address, telephone number, IP address, Universal Supply Point Code (CUPS), handwritten or digital signature, voice (e.g. recordings of telephone conversations), image.
Username and password details register for or access Nedgia apps or web platforms.
Data on social circumstances, such as the characteristics of your home or commercial premises.
Data associated with the supply point, such as: contract numbers, contracted power, applicable access toll, energy consumption, consumption history, queries, requests and complaints made, as well as any other information associated with these contracts.
Academic and professional data, such as training, professional activity, employer, position, membership of associations, professional groups or other organisations.
Browsing data and data on the use of Nedgia’s digital channels (when you provide consent), in addition to other data collected through the use of Nedgia apps or devices (when you have provided authorisation for this purpose by activating the corresponding permissions in the Nedgia app, or when you have provided your consent in another way).

III. PURPOSE OF PROCESSING, LAWFUL BASIS, RECIPIENTS AND STORAGE PERIOD

The table below contains information on each of the data processing actions undertaken by Nedgia:

Data controller: company responsible for the processing of your personal data for the corresponding purpose.
Processing purpose: reason why Nedgia processes your personal data.
Legal grounds: the legal grounds that entitle Nedgia to process your personal data for each one of the purposes described. When the basis is your consent, it means that your data will only be processed for that purpose when you have previously indicated that you consent to such processing through a statement or a clear affirmative action, in which case you have the right to withdraw your consent at any time, without retroactive effect, if you so wish. When the lawful basis is a legitimate interest, Nedgia will have made a considered judgement between the legitimate interest sought by Nedgia and your interests or your fundamental rights and freedoms, concluding that the former overrides the latter. You may request more information on this considered judgement by contacting the Data Protection Officer via the channels indicated in this Privacy Policy. Furthermore, we remind you that you have the right to object to any personal data processing action that is based on a legitimate interest. You may exercise this right through the channels indicated in this Privacy Policy.
Recipients: those third parties with whom, as the case may be, your personal data may be shared and the reason for such action. Generally speaking, for any of the purposes defined in this Section III, Nedgia will be obliged to share your personal data with third parties with whom it is legally required to do so. Furthermore, certain suppliers and service providers contracted by Nedgia may also have access to your personal data so that, as data processors, they may assist Nedgia in achieving the corresponding processing purpose. Said suppliers will be party to a data processing contract in order to guarantee legal compliance in terms of personal data protection.
Storage period: period of time for which Nedgia will process your personal data. However, pursuant to applicable legislation, your data may subsequently remain blocked in our systems so that it can potentially be provided to courts and tribunals, the Public Prosecutor’s Office or competent public bodies for the purpose of establishing possible liabilities stemming from the processing activity, and only for the limitation period thereof.

A. BEFORE YOU HAVE A NATURAL GAS SUPPLY

When you are interested in a natural gas supply installation or initiate an application process for connection to the network and a natural gas supply by providing your personal data, these data may be processed by Nedgia for the following purposes:

DATA CONTROLLER	PROCESSING PURPOSE	LAWFUL BASIS	RECIPIENTS	STORAGE PERIOD	COMMENTS
Nedgia, S. A.	To contact you by any means for the purpose of sending you advertising or promotional information about the installation of natural gas, as well as commercial communications aimed at promoting gas as a supply.	The consent that you provide.	Suppliers and service providers contracted by Nedgia may have access to your personal data so that, as data processors, they may assist Nedgia in achieving the corresponding processing purpose.	Nedgia will keep and process your data for this purpose until you revoke your consent or object to the processing of your data for this purpose. Subsequently, data blocking obligations imposed by legislation may be applicable.	In order to provide or send you this advertising or promotional information, we will use the identification and contact details you have given us. You have the right to withdraw your consent at any time and free of charge, by sending your request to any of the addresses indicated in this Privacy Policy for the exercise of data protection rights.
Nedgia, S. A.	If you entered your data on our website to initiate a network connection request and to register for natural gas and you have expressly authorised it, to contact you to help you complete the process initiated.	The consent given by you through our online form.	Suppliers and service providers contracted by Nedgia may have access to your personal data so that, as data processors, they may assist Nedgia in achieving the corresponding processing purpose.	Nedgia will only keep and process your data for this purpose until the first of the following events occurs: (i) One month has passed since you gave your consent. (ii) You revoke your consent. Subsequently, data blocking obligations imposed by legislation may be applicable.	Nedgia will use the identification and contact details that you have provided when contacting you for this purpose. You have the right to withdraw your consent at any time and free of charge, by sending your request to any of the addresses indicated in this Privacy Policy for the exercise of data protection rights.
The Nedgia distributor for your geographical area	To manage and process your network connection request and to register for natural gas, as well as to contact you to inform you about the situation and status, and answer any questions during the registration process.	To undertake the contract entered into with you or implement pre-contractual measures at your request.	Suppliers and service providers contracted by Nedgia may have access to your personal data so that, as data processors, they may assist Nedgia in achieving the corresponding processing purpose.	Nedgia will keep and process your data for this purpose until the process of connecting to the network and beginning natural gas service is completed. If this process is cancelled or is not completed for any reason, your data will be kept for a maximum of 6 months from the last action taken as part of this process. Subsequently, data blocking obligations imposed by legislation may be applicable.	To carry out the process of connecting to the natural gas network and beginning natural gas service, you will be asked for some data that are essential for this purpose, so we will not be able to manage your request and inform you about the status if you do not provide them.
Nedgia, S. A.	Conducting surveys or market research.	The consent that you provide.	Suppliers and service providers contracted by Nedgia may have access to your personal data so that, as data processors, they may assist Nedgia in achieving the corresponding processing purpose.	Nedgia will keep and process your data for this purpose until you revoke your consent or object to the processing of your data for this purpose. Subsequently, data blocking obligations imposed by legislation may be applicable.	A market study is a research project conducted by Nedgia that includes asking the supply point owners questions to determine their opinion on different aspects of the energy market, perception of the different sources of energy supply, and, depending on the results obtained, to make decisions on how to act in that market.
Nedgia, S. A.	To share your personal data with companies with which we have partnership agreements so that they may send you, including by electronic means, commercial communications relating to their products and services.	The consent that you provide.	Your personal data may be disclosed to other organisations operating in the sectors described in the ‘Comments’ column.	Nedgia will keep and process your data for this purpose until you revoke your consent or object to the processing of your data for this purpose. Subsequently, data blocking obligations imposed by legislation may be applicable.	To share your personal data with companies with which we have partnership agreements so that they may send you, including by electronic means, commercial communications relating to their products and services.
Nedgia, S.A.	To contact you by any means, including by email or other equivalent means of electronic communication, to send you commercial communications related to products or services from Nedgia’s third-party partners.	The consent that you provide.	Suppliers and service providers contracted by Nedgia may have access to your personal data so that, as data processors, they may assist Nedgia in achieving the corresponding processing purpose.	Nedgia will keep and process your data for this purpose until you revoke your consent or object to the processing of your data for this purpose. Subsequently, data blocking obligations imposed by legislation may be applicable.	To contact you by any means, including by email or other equivalent means of electronic communication, to send you commercial communications related to products or services from Nedgia’s third-party partners.

B. WHEN YOU ARE THE OWNER OF A SUPPLY POINT

You acquire supply point owner status when you have signed a natural gas supply contract with a supply company.
Thus, when you are a supply point owner, your personal data may be processed by Nedgia for the purposes described below.

DATA CONTROLLER	PROCESSING PURPOSE	LAWFUL BASIS	RECIPIENTS	STORAGE PERIOD	COMMENTS
The Nedgia distributor for your geographical area	Compliance with the obligations of the distribution company to manage the supply point (e.g. processing readings, managing operations and support in the event of emergencies, complaints, etc.)	Compliance with a legal obligation	Suppliers and service providers contracted by Nedgia may have access to your personal data so that, as data processors, they may assist Nedgia in achieving the corresponding processing purpose.	Nedgia will keep and process your data for this purpose for as long as is necessary to fulfil the purpose described. Subsequently, data blocking obligations imposed by legislation may be applicable.	Your data is provided to Nedgia by the gas supply companies to complete the registration process in accordance with the legally established procedures and is subsequently used by Nedgia to fulfil its legal obligations as a distribution company, to manage your supply point. These obligations, inter alia, are included in Article 10.3 of Royal Decree 1434/2002, of 27 December, which regulates the activities of transport, distribution, commercialisation, supply and authorisation procedures for natural gas facilities, including: distribution network installation maintenance; conducting periodic inspections of receiving installations with the frequency set out in regulations; meter readings and management; handling emergencies; managing a database of users connected to the distribution network
The Nedgia distributor for your geographical area	To inform you of the need to conduct the periodic inspection of the common and/or individual receiving installation of your supply point.	Compliance with a legal obligation	Suppliers and service providers contracted by Nedgia may have access to your personal data so that, as data processors, they may assist Nedgia in achieving the corresponding processing purpose.	Nedgia will keep and process your data for this purpose for as long as is necessary to fulfil the purpose described. Subsequently, data blocking obligations imposed by legislation may be applicable.	Additional Provision One of Royal Decree 984/2015, of 30 October, which regulates the organised gas market and third-party access to natural gas system installations, establishes the obligation of gas distribution companies to notify users connected to their network of the need to conduct the periodic inspection of common receiving installations and/or individual installations of the supply points connected to their networks, with the frequency established in current regulations on quality and industrial safety.
The Nedgia distributor for your geographical area	To contact you to send you, by any means, information related to your natural gas supply point and associated services (e.g. documentation related to operations at the supply point, campaigns to update your data, etc.). These are not commercial communications.	Nedgia’s legitimate interest in ensuring, certifying and documenting the correct development of the operations and maintenance and improvement actions of its distribution networks and receiving installations as required by gas sector regulations. Nedgia does not see any detriment to you arising from this processing and believes that you can reasonably expect to be informed of such matters relating to your relationship with Nedgia.	Suppliers and service providers contracted by Nedgia may have access to your personal data so that, as data processors, they may assist Nedgia in achieving the corresponding processing purpose.	Nedgia will only keep and process your data for this purpose until the first of the following events occurs: (i) You cease to be a supply point owner. (ii) You exercise your right to object. Subsequently, data blocking obligations imposed by legislation may be applicable.	You may object to the processing of your data for this purpose at any time and free of charge by submitting your request to any of the addresses indicated in this Privacy Policy for the purpose of exercising your data protection rights.
The Nedgia distributor for your geographical area	To contact you to send you, by email, information related the benefits of having natural gas. These are not commercial communications.	Nedgia’s legitimate interest in ensuring, certifying and documenting the correct development of the operations and maintenance and improvement actions of its distribution networks and receiving installations as required by gas sector regulations. Nedgia does not see any detriment to you arising from this processing and believes that you can reasonably expect to be informed of such matters relating to your relationship with Nedgia.	Suppliers and service providers contracted by Nedgia may have access to your personal data so that, as data processors, they may assist Nedgia in achieving the corresponding processing purpose.	Nedgia will only keep and process your data for this purpose until the first of the following events occurs: (i) You cease to be a supply point owner. (ii) You exercise your right to object. Subsequently, data blocking obligations imposed by legislation may be applicable.	You may object to the processing of your data for this purpose at any time and free of charge by submitting your request to any of the addresses indicated in this privacy policy for the purpose of exercising your data protection rights.
The Nedgia distributor for your geographical area	To contact you to determine your degree of satisfaction and quality of service received in relation to your supply point. You may request that any calls be recorded. This includes calls to determine the reasons for cancellation in the event that you decide to stop the gas supply.	Nedgia’s legitimate interest in assessing the quality of the services provided, both by Nedgia itself and by those partners or third parties with whom it works in relation to such services, is essential to ensure adequate quality standards. Nedgia believes that, when you receive a service from Nedgia, you can reasonably expect to be consulted in this regard.	Suppliers and service providers contracted by Nedgia may have access to your personal data so that, as data processors, they may assist Nedgia in achieving the corresponding processing purpose.	Nedgia will only keep and process your data for this purpose until the first of the following events occurs: (i) You cease to be a supply point owner. (ii) You exercise your right to object. Subsequently, data blocking obligations imposed by legislation may be applicable.	Responding to these surveys will always be voluntary. You may object to the processing of your data for this purpose at any time and free of charge by submitting your request to any of the addresses indicated in this privacy policy for the purpose of exercising your data protection rights.
Nedgia, S. A.	Conducting surveys or market research.	Nedgia’s legitimate interest in knowing the public’s perception of the energy sector in general, and of Nedgia’s image and of natural gas as an energy source in particular, as well as their interests and needs with respect to energy supply. Nedgia considers that the individuals consulted, as owners of supply points in Nedgia’s network, have a reasonable expectation of being asked about the aspects indicated.	Suppliers and service providers contracted by Nedgia may have access to your personal data so that, as data processors, they may assist Nedgia in achieving the corresponding processing purpose.	Nedgia will only keep and process your data for this purpose until the first of the following events occurs: (i) You cease to be a supply point owner. (ii) You exercise your right to object. Subsequently, data blocking obligations imposed by legislation may be applicable.	A market study is a research project conducted by Nedgia that includes asking the supply point owners questions to determine their opinion on different aspects of the energy market, perception of the different sources of energy supply, and, depending on the results obtained, to make decisions on how to act in that market. The information obtained during market studies is analysed in an aggregated manner. As a result, the information provided by you will be made anonymous so that it cannot be directly associated with you. You may object to the processing of your data for this purpose at any time and free of charge by submitting your request to any of the addresses indicated in this privacy policy for the purpose of exercising your data protection rights.
Nedgia, S. A.	To manage your registration as a user in the Private Customer Area. (when you have requested it), which will enable you to access it and make use of the functionalities it offers.	The consent that you provide when registering through the online form.	Suppliers and service providers contracted by Nedgia may have access to your personal data so that, as data processors, they may assist Nedgia in achieving the corresponding processing purpose.	Nedgia will keep and process your data for this purpose until the first of the following events occurs: (i) You cease to be a supply point owner. (ii) You withdraw your consent or otherwise terminate your membership in the Private Customer Area. Subsequently, data blocking obligations imposed by legislation may be applicable.	Data marked as required in the corresponding registration form are necessary to properly manage your registration as a user, so you will not be able to register if you do not provide them.. Nedgia will only use the data provided by you during the registration process in the Private Customer Area for this purpose. You have the right to withdraw your consent at any time and free of charge, by sending your request to any of the addresses indicated in this Privacy Policy for the exercise of data protection rights. Withdrawing this consent will make it impossible for you to remain a user of the Nedgia Private Customer Area, preventing you from accessing it and making use of the features it offers.
Nedgia, S. A.	To share your personal data with companies with which we have partnership agreements so that they may send you, including by electronic means, commercial communications relating to their products and services.	The consent that you provide.	Your personal data may be disclosed to other organisations operating in the sectors described in the ‘Comments’ column.	Nedgia will keep and process your data for this purpose until you revoke your consent or object to the processing of your data for this purpose. Subsequently, data blocking obligations imposed by legislation may be applicable.	To share your personal data with companies with which we have partnership agreements so that they may send you, including by electronic means, commercial communications relating to their products and services.
Nedgia, S. A.	To contact you by any means, including by email or other equivalent means of electronic communication, to send you commercial communications related to products or services from Nedgia’s third-party partners.	The consent that you provide.	Suppliers and service providers contracted by Nedgia may have access to your personal data so that, as data processors, they may assist Nedgia in achieving the corresponding processing purpose.	Nedgia will keep and process your data for this purpose until you revoke your consent or object to the processing of your data for this purpose. Subsequently, data blocking obligations imposed by legislation may be applicable.	To contact you by any means, including by email or other equivalent means of electronic communication, to send you commercial communications related to products or services from Nedgia’s third-party partners.

C. REGARDING THOSE WHO CONTACT NEDGIA FOR DIFFERENT PURPOSES

From time to time, you may contact Nedgia, whether or not you are the owner of a supply point, to request information, quotations, make enquiries, participate in offers and/or events organised by Nedgia, or interact or conduct various other transactions with Nedgia regardless of whether or not there is a prior contractual or other relationship with Nedgia, by providing us with some of your personal data for this purpose. This data may be processed by Nedgia for the purposes described below:

DATA CONTROLLER	PROCESSING PURPOSE	LAWFUL BASIS	RECIPIENTS	STORAGE PERIOD	COMMENTS
Nedgia, S.A.	To manage and deal with requests, enquiries, information requests or requirements that you make to Nedgia and are not related to a contract previously entered into with Nedgia or as the owner of a supply point.	The consent that you give when making such a request, enquiry or requirement through any of the channels provided by Nedgia for this purpose.	Your personal data may be disclosed to the installation company whose quote you have previously selected so that they may contact you and carry out the relevant installation. Furthermore, suppliers and service providers contracted by Nedgia may have access to your personal data so that, as data processors, they may assist Nedgia in achieving the corresponding processing purpose. You are hereby informed that, for the purpose of providing customer service, your data will be accessed by providers located in Colombia, a country that does not have an adequacy decision issued by the European Commission. These data transfers are carried out on the basis of Standard Contractual Clauses approved by the European Commission, which are signed with these suppliers. If you communicate with us via WhatsApp, we inform you that WhatsApp adheres to the EU-US Data Privacy Framework, which ensures adequate protection for international data transfers to the US (we recommend you read their privacy policy).	Nedgia will only keep and process your data for this purpose until the first of the following events occurs: (i) The processing of your request or enquiry has been completed. (ii) You request their erasure or revoke the consent given. Subsequently, data blocking obligations imposed by legislation may be applicable.	The data that will be processed by Nedgia for this purpose are those provided by you when making the corresponding request, enquiry or requirement. You have the right to withdraw your consent at any time and free of charge, by sending your request to any of the addresses indicated in this Privacy Policy for the exercise of data protection rights. Withdrawing such consent means that your request or enquiry will not be processed.
The Nedgia distributor for your geographical area	Detection, management and investigation of fraud and irregularities.	Nedgia’s legitimate interest in guaranteeing the safety of its distribution networks and receiving installations as required by gas sector regulations, as well as in dealing with any unlawful actions committed against the gas distribution network. There is no detriment to you arising from this processing, and it is believed that you can reasonably expect your data to be processed for this purpose.	Suppliers and service providers contracted by Nedgia may have access to your personal data so that, as data processors, they may assist Nedgia in achieving the corresponding processing purpose.	Nedgia will keep and process your personal data for this purpose for the time required for the management and investigation of the relevant fraud or irregularity. Subsequently, data blocking obligations imposed by legislation may be applicable.
Nedgia, S.A.	To manage the organisation and development, until conclusion, of seminars, conferences, training or recreational activities, and other Nedgia events (the ‘Event’) for which you have registered. This may include the issue of attendance certificates, where applicable.	The consent that you provide when registering for the Event.	Suppliers and service providers contracted by Nedgia may have access to your personal data so that, as data processors, they may assist Nedgia in achieving the corresponding processing purpose.	Nedgia will keep and process your data for this purpose until the first of the following events occurs: (i) Three (3) months have passed since the end of the Event. (ii) You request their erasure or revoke the consent given. Subsequently, data blocking obligations imposed by legislation may be applicable.	The data that will be processed by Nedgia for this purpose are those provided by you at the time of registering for the Event. Data marked as required on the corresponding registration form are necessary to properly manage your participation in the Event, so you will not be able to register if you do not provide them. You have the right to withdraw your consent at any time and free of charge, by sending your request to any of the addresses indicated in this Privacy Policy for the exercise of data protection rights. Withdrawing the consent given at the time of registration will result in you being unable to take part in the Event.
Nedgia, S.A.	To manage the organisation, development and completion of the promotion, contest, draw or similar (the ‘Promotion’) run by Nedgia you have entered. In particular, to identify the participating users, select the winners and manage prize delivery.	The consent that you provide when registering for the Promotion.	Suppliers and service providers contracted by Nedgia may have access to your personal data so that, as data processors, they may assist Nedgia in achieving the corresponding processing purpose.	Nedgia will keep and process your data for this purpose until the first of the following events occurs: (i) Three (3) months have passed since the end of the Promotion. (ii) You request their erasure or revoke the consent given. Subsequently, data blocking obligations imposed by legislation may be applicable.	The data that will be processed by Nedgia for this purpose are those that you provide when you register for the Promotion. Data marked as required on the corresponding registration form are necessary to properly manage your participation in the Promotion, so you will not be able to register if you do not provide them. You have the right to withdraw your consent at any time and free of charge, by sending your request to any of the addresses indicated in this Privacy Policy for the exercise of data protection rights Withdrawal of the consent given on registration will result in you being unable to take part in the Promotion.
Nedgia, S.A.	To use your image and voice to disseminate the Events and/or Promotions organised by Nedgia in public or private media, including social networks, with the publication of the images and/or voice captured whilst they are held.	The consent that you provide.	Your image and voice may be subject to reproduction, dissemination and/or communication to third parties, under the terms you have been informed of in each case when registering for the corresponding Event or Promotion. Suppliers and service providers contracted by Nedgia may also have access to your personal data so that, as data processors, they may assist Nedgia in achieving the corresponding processing purpose. Suppliers and service providers contracted by Nedgia may have access to your personal data so that, as data processors, they may assist Nedgia in achieving the corresponding processing purpose.	Nedgia will keep and process your data for this purpose until you revoke your consent or request their deletion. Subsequently, data blocking obligations imposed by legislation may be applicable.	You have the right to withdraw your consent, at any time, by sending your request to any of the addresses indicated in this Privacy Policy for the exercise of data protection rights.
Nedgia, S.A.	To contact you to determine your degree of satisfaction with the service received, or with the Event or Promotion in which you have participated.	Nedgia’s legitimate interest in assessing the quality of the services provided, both by Nedgia itself and by those partners or third parties with whom it works in relation to such services, is essential to ensure adequate quality standards. We believe that, by using or receiving a Nedgia service, you can reasonably expect to be consulted in this regard.	Suppliers and service providers contracted by Nedgia may have access to your personal data so that, as data processors, they may assist Nedgia in achieving the corresponding processing purpose.	Nedgia will only keep and process your data for this purpose until the first of the following events occurs: (i) The described purpose is completed. (ii) You exercise your right to object. Subsequently, data blocking obligations imposed by legislation may be applicable.	You may object to the processing of your data for this purpose at any time and free of charge by submitting your request to any of the addresses indicated in this Privacy Policy for the purpose of exercising your data protection rights.

D. WITH RESPECT TO CONTACT PERSONS AND LEGAL REPRESENTATIVES OF COMPANIES, AS WELL AS SOLE TRADERS AND FREELANCERS, OR REPRESENTATIVES OF PROPERTY OWNERS’ ASSOCIATIONS

Nedgia may sometimes have a professional relationship with the legal company in which you provide your services, with the property owners’ associations you represent, or even with yourself if you are a sole trader or freelancer. In these cases, Nedgia may have your contact details and sometimes those relating to your role or position (together, the Professional Contact Details). This data may be processed by Nedgia for the purposes described below:

DATA CONTROLLER	PROCESSING PURPOSE	LAWFUL BASIS	RECIPIENTS	STORAGE PERIOD	COMMENTS
The Nedgia distributor for your geographical area	To maintain a professional relationship with (as appropriate): (i) The legal entity in which you provide your services (ii) You, in your capacity as a sole trader or freelancer.	Nedgia’s legitimate interest, in accordance with Article 19 of the Organic Law 3/2018 of 5 December on the Protection of Personal Data and Guarantee of Digital Rights (LOPDGDD).	Suppliers and service providers contracted by Nedgia may have access to your personal data so that, as data processors, they may assist Nedgia in achieving the corresponding processing purpose.	Nedgia will keep and process your Professional Contact Data for this purpose until you request their deletion or exercise your right to object. Subsequently, data blocking obligations imposed by legislation may be applicable.	Your Professional Contact Data may have been obtained: (i) When concluding or executing a contract or professional relationship between Nedgia and the legal entity at which you provide your services, or with yourself as a sole trader or freelancer. (ii) Through third parties, belonging to the public or private sector, or through public information or publicly available sources. (iii) Through networking or professional meetings with Nedgia members. (iv) Or after being provided to Nedgia by you or by the entity or body at which you provide your services, or by another higher entity or body to which you report. The processing of your Professional Contact Data is intended for the proper management of any relationship between Nedgia and the legal entity in which you provide your services, or with you in your capacity as a sole trader or freelancer, but your data will not be processed for the purpose of managing a relationship with you as an individual.
The Nedgia distributor for your geographical area	To maintain a professional relationship with the Owners’ Association you represent.	Nedgia’s legitimate interest in offering its services, maintaining and managing any business relationship with a Owners’ Association, whereby communication with this company is only possible through the figure of the Chairperson or any other person who is the legal representative of said Owners’ Association. Nedgia considers that data subjects acting as representatives of the Owners’ Association have a reasonable expectation of being contacted for the purposes set out above.	Suppliers and service providers contracted by Nedgia may have access to your personal data so that, as data processors, they may assist Nedgia in achieving the corresponding processing purpose.	Nedgia will only keep and process your data for this purpose until you request their deletion or exercise your right to object. Subsequently, data blocking obligations imposed by legislation may be applicable.	The processing of your Professional Contact Data is necessary in order to properly manage any relationship between Nedgia and the Owners’ Association you represent, but your data will not be processed in order to manage a relationship with you as an individual. Your contact details may have been obtained in the following ways: (i) By being provided to Nedgia by yourself or by the Owners’ Association you represent. (ii) Through third parties, belonging to the public or private sector, or through public information or publicly available sources. (iii) Through networking or professional meetings with Nedgia members.

E. OTHER PROCESSING

DATA CONTROLLER	PROCESSING PURPOSE	LAWFUL BASIS	RECIPIENTS	STORAGE PERIOD	COMMENTS
Nedgia, S.A.	To assess the quality of service provided in telephone calls when you contact Nedgia.	Nedgia’s legitimate interest in assessing the quality of the service provided to individuals who contact Nedgia to carry out administrative procedures or make an enquiry or request, as it is essential to ensure adequate quality standards. We believe that, when you receive a service from Nedgia, you have a reasonable expectation that the quality of that service will be assessed.	Suppliers and service providers contracted by Nedgia may have access to your personal data so that, as data processors, they may assist Nedgia in achieving the corresponding processing purpose.	Nedgia will only keep and process your data for this purpose until the first of the following events occurs: (i) You cease to be the holder of a supply contract. (ii) You exercise your right to object. Subsequently, data blocking obligations imposed by legislation may be applicable.	Since your voice is personal data, if your call is recorded for the purpose described above, you will be informed of this at the time the conversation is initiated. You may object to the processing of your data for this purpose at any time and free of charge by submitting your request to any of the addresses indicated in this privacy policy for the purpose of exercising your data protection rights.
The Nedgia distributor for your geographical area	To manage any requests that you submit to exercise your individual rights regarding personal data protection.	Compliance with the legal obligation imposed on the controller by Regulation (EU) 2016/679 (GDPR), and Organic Law 3/2018, of 5 December, on the Protection of Personal Data and guarantee of digital rights (LOPDGDD).	Suppliers and service providers contracted by Nedgia may have access to your personal data so that, as data processors, they may assist Nedgia in achieving the corresponding processing purpose.	Nedgia will keep and process your data for this purpose for as long as is necessary to fulfil the purpose described. Subsequently, data blocking obligations imposed by legislation may be applicable.
The Nedgia distributor for your geographical area	To comply with legal obligations imposed by the regulations applicable to Nedgia.	Compliance with a legal obligation applicable to Nedgia.	Your personal data will be disclosed to the corresponding third parties when Nedgia is legally obliged to do so. Furthermore, suppliers and service providers contracted by Nedgia may have access to your personal data so that, as data processors, they may assist Nedgia in achieving the corresponding processing purpose.	Nedgia will keep and process your data for this purpose for as long as is necessary to fulfil the purpose described. Subsequently, data blocking obligations imposed by legislation may be applicable.	Occasionally, Nedgia must process your personal data, usually by disclosing it to a third party, in order to comply with an applicable legal obligation. The following are the most relevant cases arising from energy sector regulations: – Disclosure of data to gas suppliers, or to the National Commission for Markets and Competition, where required by regulations governing access to gas networks, registration, cancellation, changes of supplier, billing for consumption, and other processes specific to Nedgia’s activity, which are fully regulated and must be carried out in accordance with the regulations, primarily Law 34/1998 of 7 October on the hydrocarbons sector, and Royal Decree 1434/2002 of 27 December, which regulates the activities of transport, distribution, commercialisation, supply and authorisation procedures for natural gas installations, and all other supplementary regulations implementing them. – Royal Decree 984/2015, of 30 October, which regulates the organised gas market and third-party access to natural gas system installations. In addition to this, Nedgia is also legally obliged to communicate any personal data required by the competent judicial or administrative authorities, as well as by law enforcement agencies. For example, those derived from the following legislation: – Art. 7 of Organic Law 7/2021 of 26 May on the protection of personal data processed for the purposes of the prevention, detection, investigation and prosecution of criminal offences and the application of criminal penalties. – Art.18 of Law 39/2015, of 1 October, of the Common Administrative Procedure of Public Administrations.
The Nedgia distributor for your geographical area	To exchange your updated data with your gas supply company.	Nedgia’s legitimate interest in updating the details of gas supply point holders in order to streamline and improve the effectiveness of contacts with such holders Nedgia does not see any detriment to you arising from this processing given that Nedgia only has supply holder data in order to carry out its activity as an authorised distributor in the geographical area in which your supply point is located.	Your gas supplier. Furthermore, suppliers and service providers contracted by Nedgia may have access to your personal data so that, as data processors, they may assist Nedgia in achieving the corresponding processing purpose	Nedgia will only keep and process your data for this purpose until the first of the following events occurs: (i) You cease to be the holder of a supply contract. (ii) You exercise your right to object. Subsequently, data blocking obligations imposed by legislation may be applicable.	All supply point holders are deemed to reasonably expect that both their distributor and their supply company will have their data updated at all times, so that both can carry out their activities regulated in sectoral regulations. Failure to process this data would mean that your distribution company and your supply company could be using inaccurate or obsolete data, causing delays and even the impossibility of carrying out certain activities that, according to sectoral regulations, must be carried out by these companies. You may object to the processing of your data for this purpose at any time and free of charge by submitting your request to any of the addresses indicated in this privacy policy for the purpose of exercising your data protection rights.
The Nedgia distributor for your geographical area	To encourage new natural gas supply point registration by communicating technical information to third parties regarding supply points that have the necessary infrastructure to register a new supply.	Nedgia’s legitimate interest in promoting network connections and the commissioning of new supplies as part of its regulated distribution activity. Nedgia does not believe that you are caused any harm due to this processing, as Nedgia only has technical data relating to your supply point as a result of its activity as an authorised distributor in the geographical area where your supply point is located.	Technical data relating to the supply point, specifically concerning the availability of infrastructure required to connect the supply, may be disclosed to supply companies with whom a collaboration agreement has previously been formalised. Furthermore, suppliers and service providers contracted by Nedgia may have access to your personal data so that, as data processors, they may assist Nedgia in achieving the corresponding processing purpose.	Nedgia will only keep and process your data for this purpose until the first of the following events occurs: (i) Your supply point is commissioned and connected to the natural gas network. (ii) You exercise your right to object. Subsequently, data blocking obligations imposed by legislation may be applicable.	As the authorised natural gas distributor in the geographical area where your supply point is located, Nedgia will only process technical data relating to your supply point (Universal Supply Point Code, metres from the network, pressure) for this purpose. Nedgia does not have your identification or contact details.
The Nedgia distributor for your geographical area	To promote the regularisation of supply points that are administratively cancelled but are still in use, by providing technical information relating to the supply point to supply companies participating in the Public Partnership Offer, with the aim of facilitating the conclusion of a supply contract and preventing an active supply point from remaining without an associated contract.	Nedgia’s legitimate interest in promoting, encouraging and facilitating the regularisation of active supply points that are administratively cancelled but still showing consumption, ensuring they are properly linked to a supply company and contributing to the proper functioning of the gas system. Nedgia believes that this processing falls within the reasonable expectations of the data subject and that it outweighs any potential harm associated with it, in accordance with the relevant balancing test.	Technical data relating to the supply point may be disclosed to supply companies participating in Nedgia’s Public Partnership Offer. Furthermore, suppliers and service providers contracted by Nedgia may have access to your personal data so that, as data processors, they may assist Nedgia in achieving the corresponding processing purpose.	Nedgia will keep and process the data for this purpose until the first of the following events occurs: (i) the supply point has a contract with a supply company; (ii) the data subject exercises their right to object. Subsequently, legal blocking obligations may be applicable.	For this purpose, only the essential technical data associated with the supply point will be processed, specifically the CUPS and the address. Before disclosing this data, Nedgia will inform the data subject by sending a notice to the address associated with the supply point and will enable them to exercise their right to object, which will be granted in all cases.

IV. INTERNATIONAL DATA TRANSFERS.

If, in order to process your data for the indicated purposes, said data needs to be transferred outside of the European Economic Area (“EEA”), such transfers would take place after signing the standard data protection clauses adopted by the European Commission for international data transfers with said companies located outside of the EEA or after adopting the other appropriate safeguards provided for under applicable regulations. The “Recipients” column of the previous section includes more detailed information on those cases in which this type of transfer takes place.

V. DATA PROTECTION OFFICER

Nedgia has appointed a Data Protection Officer, whose contact details are as follows:
– Postal address: Avenida de América, 38 – CP 28028 Madrid
– Email: dpd-dpo@naturgy.com

VI. RIGHTS REGARDING YOUR PERSONAL DATA

The rights to which you are legally entitled, when applicable, are as follows:

RIGHT	CONTENT
Access	You may consult any of your personal data that may be subject to processing activities by Nedgia.
Rectification	You may change your personal data if they are inaccurate or incomplete.
Erasure	You may ask for your personal data to be erased.
Objection	You may ask for your personal data not to be processed on the basis of legitimate interest. Furthermore, you may object to the processing of your personal data for direct marketing purposes, including the creation of profiles when this action is related to direct marketing.
Limitation on processing	You may request that the processing of your data be restricted: – While the accuracy of your data is being challenged. – When the processing is unlawful, but you object to the deletion of your data and request the limitation of their use. – When Nedgia no longer needs to process your data but you need them to take or defend against legal action. – When you have objected to the processing of your data to perform a mission of public interest or fulfil a legitimate interest, while verifying whether the lawful basis for processing outweighs your objection.
No Automated Decisions	You may ask not to be the subject of decisions based solely on the automated processing of your data.
Withdraw consent	At any time and without retroactive effect, you may withdraw any consent you may have provided in the past to authorise the processing of your data for a specific purpose.
Portability	You may receive, in a digital format, the personal data that you provided to us and pass them on to another company.

You may exercise the aforementioned rights via the following channels:

Email: derechoslopdnedgia@naturgy.com
Postal address: FAO: Nedgia Customer Services, Plaça del Gas nº 2, 08003 Barcelona.

The subject line of your message must state “Solicitud Protección de Datos-Ejercicio de derechos”. Since these are individual rights, Nedgia must verify that they are exercised by the data subject or an authorised person. Thus, if Nedgia has any doubts about your identity, it may request additional information for confirmation purposes, for example, a copy of your identity document (DNI/NIE), passport or equivalent. You may also use your electronic signature instead of your identity document (DNI). If rights are exercised by someone authorised by the data subject, evidence of the identity of the authorised party must be provided and the authorisation accredited.

Nedgia will provide the requested information within one month from receiving the request. Said period may be extended to two months, if necessary, based on the complexity and number of requests.

If you believe that we have not duly processed your personal data, you may contact the Data Protection Officer via any of the aforementioned channels.

In any event, we hereby inform you that, if you believe that the regulations governing personal data protection have been violated in the processing of your personal data, you are also entitled to lodge a complaint with the competent supervisory authority (e.g. Spanish Data Protection Agency – www.aepd.es).

July 2026