Privacy Policy for the WhatsApp Communication Channel

Controller	FONTESTAD CITRUS, S.L.
Address	Ctra. CV-32, km 9, 46136 Museros (Valencia), Spain
Channel	WhatsApp Business Corporate Account
Last updated	[October 19, 2026]

The purpose of this policy is to provide information, in accordance with Articles 13 and 14 of Regulation (EU) 2016/679, General Data Protection Regulation (GDPR), and Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights (LOPDGDD), regarding the processing of personal data carried out by FONTESTAD CITRUS, S.L. through its WhatsApp Business corporate account, including the use of automated tools for initial interview management and appointment scheduling. This information complements, where applicable, the general Data Protection Policy published on the corporate website and the specific clauses provided in selection processes, employment relationships, and contractual or commercial relationships.

1. Identity of the Data Controller

Controller	FONTESTAD CITRUS, S.L.
Tax ID (NIF)	B98930324
Address	Ctra. CV-32, km 9, 46136 Museros (Valencia), Spain
Privacy Email	rrhhalmacen@fontestad.com
Phone	961 450 655

FONTESTAD CITRUS, S.L., hereinafter "FONTESTAD," is responsible for the processing of personal data carried out through this channel when it determines its purposes and means.

2. Subjective Scope of the Channel

The corporate WhatsApp channel will be used exclusively to communicate with the following categories of data subjects:

Candidates participating in selection processes.
FONTESTAD employees and members of harvesting crews.
Independent contractors.
Self-employed drivers and drivers and staff of transport companies that move fruit from the fields.
Representatives and contact persons of suppliers, contractors, and collaborating companies.

3. Categories of Processed Data

Depending on the relationship maintained and the purpose of each communication, FONTESTAD may process the following categories of data:

Identification and contact data: first name, last name, and phone number.
Professional data: company, crew, or entity of affiliation; professional or contractual status; position or function.
Management and availability data: appointments, calls for work, availability, and assignment of jobs or services.
Logistics and operational location data: orchard, farm, meeting point, loading point, destination, date, and time of service.
Transport data: license plate, load reference, shipment, and other information necessary to coordinate the service.
Data contained in DeCAs and associated documentation, to the extent necessary to manage and verify the operation.
Content of messages, responses, files, and exchanged receipts.
Technical data and metadata linked to the operation of the communication.

Please do not send specially protected data or unnecessary documentation via WhatsApp, particularly medical information, biometric data, criminal records, bank details, passwords, or full copies of identification documents, unless expressly requested by FONTESTAD and a suitable legal basis exists.

4. Purposes of Processing

4.1. Selection processes and interviews via bot

FONTESTAD may use WhatsApp and an automated assistant to:

Conduct an initial interaction or structured interview with the candidate.
Collect information linked to the process, such as availability, schedule preferences, and necessary professional data.
Propose, schedule, confirm, modify, or cancel interviews.
Send reminders and communications related to the candidacy.
Refer the conversation to Human Resources staff when necessary.

The automated system will identify itself as such. Unless otherwise expressly stated and legally required guarantees are established, the bot will not independently make hiring, exclusion, or assessment decisions with legal or similar effects. The candidate may request the intervention of a person.

4.2. Communications with employees and crews

The channel may be used to:

Send so-called "orchard dispatches," consisting of calling crews and indicating the orchard or farm where they must perform harvesting tasks.
Indicate date, time, meeting point, and necessary organizational conditions.
Communicate changes, cancellations, or operational incidents.
Coordinate harvesting activity and confirm receipt of instructions.
Send other communications strictly related to the organization and execution of work.

These communications will respect the workday, rest periods, vacations, and the right to digital disconnection. The channel does not imply a general obligation of availability or response outside of working hours.

4.3. Communications with carriers, independent contractors, and collaborating companies

Send "orchard dispatches" addressed to self-employed drivers and drivers of transport companies, calling them to the corresponding orchard or farm.
Communicate the orchard, farm, or loading point they must attend.
Indicate date, time, load reference, destination, and other logistical instructions.
Manage incidents related to the collection and transport of fruit.
Confirm the acceptance, modification, or completion of the service.

When the recipient acts as a contact person for a company, their data will be used exclusively to manage the professional or commercial relationship maintained with said entity.

4.4. Sending and management of DeCA

FONTESTAD may send or receive DeCAs and associated information through WhatsApp when necessary to document or manage transport, identify the service, vehicle, shipment, origin, or destination, comply with legal or administrative obligations, verify the operation, and manage incidents.

Whenever possible, WhatsApp will be used as an auxiliary notification or delivery channel. Documentation that must be preserved will be incorporated into the enabled corporate systems, avoiding its only copy remaining on the mobile device or in the conversation.

4.5. Channel management and compliance verification

FONTESTAD may process data to manage registrations and cancellations, keep evidence of channel acceptance, prevent improper use, address requests and claims, maintain the security of the solution, and verify compliance with its obligations.

4.6. Other personnel communications

FONTESTAD may use the channel to send its employees other communications related to personnel management and the employment relationship, such as organizational notices, reminders, calls for meetings, or general information. Before incorporating new types of communication involving purposes other than those described, FONTESTAD will update this policy and inform the affected persons in advance. In no case will WhatsApp be used to send commercial communications.

5. Legal Bases for Processing

5.1. Candidates

The processing necessary to manage a candidacy, conduct the initial interview via bot, and schedule interviews is based on the application of pre-contractual measures at the request of the data subject, in accordance with Article 6.1.b) of the GDPR. The preservation of data for consideration in future selection processes will be based on the candidate's consent (Article 6.1.a) of the GDPR), which may be withdrawn at any time.

5.2. Employees

The processing may be based, depending on the specific communication, on the execution of the employment relationship, on compliance with legal obligations applicable to FONTESTAD and, where appropriate, on the legitimate interest of effectively organizing its activity after assessing the necessity, proportionality, and rights of the affected persons. When none of these bases are sufficient, consent will be requested.

5.3. Independent contractors and carriers

The processing may be based on the application of pre-contractual measures, the execution of the service or transport contract, and compliance with legal obligations.

5.4. Contact persons of collaborating companies

The processing is based on the legitimate interest of FONTESTAD and the represented entity in maintaining and managing their professional or commercial relationships, in accordance with applicable regulations.

5.5. Use of WhatsApp as a channel

Prior to sending messages via WhatsApp, FONTESTAD will request the data subject's acceptance of the use of this channel as a means of communication, indicating the categories of accepted communications. This acceptance refers exclusively to the use of WhatsApp as a means of communication and does not constitute the legal basis for the processing of data, which is supported by the bases indicated in the previous sections for each group. Acceptance may be withdrawn at any time, without prejudice to FONTESTAD being able to carry out necessary communications to manage the employment, contractual, or professional relationship by other means.

6. Nature of the Channel and Alternative Means

The use of WhatsApp on a personal device by an employee will be voluntary, unless there is a duly justified organizational need and FONTESTAD provides a suitable corporate device or means. Refusal to use WhatsApp on a personal phone will not generate unfavorable consequences.

When necessary, FONTESTAD will enable reasonable alternative channels, such as phone calls, SMS, email, corporate applications, or other available means.

The data subject may request to stop receiving communications via WhatsApp by sending "BAJA WHATSAPP" (UNSUBSCRIBE WHATSAPP).

7. Recipients and Providers

The data may be accessible, within the corresponding purpose, to:

Authorized departments and personnel of FONTESTAD who need to know the information.
Messaging, automation, hosting, support, integration, or maintenance providers.
The provider of the bot or the communication management platform: Meta Platforms, Inc.
WhatsApp Ireland Limited and, where applicable, Meta Platforms Ireland Limited, as providers of the WhatsApp Business platform, which will process certain data according to their own terms and privacy policies.
Advisors, auditors, and providers who must access the data to provide their services.
Public administrations, judicial bodies, and competent authorities when a legal obligation exists.

Providers that process data on behalf of FONTESTAD must be bound by the corresponding data processing agreement and act according to the company's documented instructions.

8. International Transfers

The use of WhatsApp and certain technological providers may involve data processing from countries located outside the European Economic Area. When international transfers occur, FONTESTAD will verify that they have a valid basis and adequate safeguards, such as an adequacy decision or standard contractual clauses, along with any necessary supplementary measures.

9. Retention Periods

Data will be kept only for the time necessary for the indicated purposes and, subsequently, during the applicable legal retention and limitation periods. In particular:

Candidacies: during the selection process and the additional period necessary to address possible liabilities. When the candidate has consented to their consideration for future processes, the data will be kept until the withdrawal of consent or, at most, for 2 years.
Employment relationship: during the term of the relationship and subsequent legal periods.
Independent contractors, carriers, and collaborating companies: during the contractual or commercial relationship and subsequent legal periods.
DeCA and transport documentation: during the legally required period according to the nature of the document and the operation.
Authorizations and cancellations: during the time necessary to verify their existence, scope, and withdrawal.
Conversations and files on WhatsApp: during the time strictly necessary to manage the communication and document relevant actions, in accordance with the internal retention policy.

FONTESTAD will apply periodic reviews and will delete or block information when it is no longer necessary.

10. Rights of Data Subjects

Data subjects may exercise the rights of access, rectification, erasure, objection, restriction of processing, and portability, as well as withdraw the consent provided and, where applicable, exercise the right not to be subject to decisions based solely on automated processing.

Requests may be sent in writing to FONTESTAD CITRUS, S.L., Ctra. CV-32, km 9, 46136 Museros (Valencia), or to rrhhalmacen@fontestad.com indicating the right they wish to exercise and accompanying a copy of their ID or equivalent identification document when necessary to verify the applicant's identity.

If the data subject considers their right to personal data protection violated, they may file a claim with the Spanish Data Protection Agency (www.aepd.es).

11. Security, Confidentiality, and Responsible Use

FONTESTAD will apply appropriate technical and organizational measures to protect the data. In particular:

It will use corporate or expressly authorized accounts, numbers, and devices.
It will limit access to personnel who need to know the information.
It will avoid groups that reveal the phone numbers of their members when individual messages, broadcast lists, or other more suitable mechanisms can be used.
It will apply the principle of minimization, avoiding excessive or unnecessary data.
It will establish procedures for registration, modification, and cancellation of authorized users.
It will withdraw access when the employment or professional relationship ends.
It will transfer documentation that must be preserved to corporate systems.
It will manage cancellation and objection requests and periodically review conversations and files.

12. Bot Operation and Human Attention

When the conversation is initiated or managed by an automated system, the user will be informed that they are interacting with a bot. The system may collect responses, propose dates and times, confirm appointments, and transfer the conversation to a person at FONTESTAD.

The data subject may request human attention through the option: Call an operator at 96 145 06 55 or by sending an equivalent message to rrhhalmacen@fontestad.com.

13. Unsubscribing from the Channel

The recipient may stop receiving communications via WhatsApp at any time by:

Responding "BAJA WHATSAPP".
Blocking the corporate number.
Writing to rrhhalmacen@fontestad.com.

Unsubscribing from WhatsApp will not prevent FONTESTAD from sending necessary communications to comply with legal, labor, or contractual obligations by other means.

14. Policy Update

FONTESTAD may update this policy when the purposes, providers, technology used, or applicable regulations change. The current version will be available on the corporate website.

Last updated date: October 19, 2026

ANNEX I. WhatsApp Channel Acceptance Text

ACCEPTANCE OF COMMUNICATIONS VIA WHATSAPP

I accept that FONTESTAD CITRUS, S.L. uses the phone number provided to send me communications via WhatsApp.

I have been informed that I can withdraw this acceptance and request to unsubscribe from the channel at any time, without prejudice to FONTESTAD being able to carry out necessary communications to manage the employment, contractual, or professional relationship by other means. Privacy Policy