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Approved by SMARTEDTECH SL (owner) · Effective 1 listopada 2026

Gustix International Transfer Schedule

1. Map the actual transfer

Identify exporter, importer, controller/processor role, country, recipient function, categories/subjects, frequency, onward access and hosting/support access. No default assumption is made that a Spanish domain stays in the EEA or that a UK domain uses a UK-established operator. If no restricted transfer occurs, record that fact and maintain a change trigger rather than attaching irrelevant SCCs.

2. Select and execute the instrument

Use a current applicable adequacy decision only within its scope and validity. Otherwise select the correct EU SCC module and complete its parties, annexes, technical/organizational measures and subprocessor details; keep the Commission's mandatory clauses intact. For a UK restricted transfer use the appropriate current UK IDTA or approved UK Addendum and complete its tables. This explanatory schedule is not itself a signed SCC/IDTA and does not replace their operative text.

3. Assessment and controls

Assess actual destination law, government access, data sensitivity and practical safeguards. Document access controls, encryption/key control, minimization, pseudonymization, complaint/redress and onward-transfer limits where relevant. Reassess material vendor, country or legal changes. If an instruction cannot be lawfully fulfilled, pause that transfer and seek a compliant alternative; do not paper over it with generic consent.

4. Release condition

No transfer is marked approved until the data map, importer identity, executed instrument, annexes, impact/risk assessment and supplementary measures are recorded. Data subjects retain the instrument's enforceable rights; disclose a lawful way to obtain relevant safeguards without disclosing others' secrets.

Platform-specific terms

Platform role: intermediary, not seller

1. The Operator operates a platform that enables users to discover, contact, book, order from or contract with third-party providers. The Operator is not a party to any contract between a user and a provider unless expressly stated on the order summary.

2. The Operator does not hold, custody or escrow funds for a provider's receivable unless a signed collection mandate exists and the order summary identifies the Operator as payment collector.

3. Providers are independent businesses or professionals. They are not employees, agents or partners of the Operator, and the Operator does not supervise their work, licensing or compliance except as expressly described in the provider verification section.

4. Nothing in this clause limits the Operator's own obligations in relation to its platform service, its own subscriptions or its own data processing.

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Accommodation, reservations and date-specific services

1. The accommodation provider, restaurant or venue is the supplier of the service and the party to the booking contract. The booking is formed when the supplier confirms availability through the platform or by the method stated on the listing.

2. Cancellation, no-show and modification rules are those of the supplier shown on the listing at the time of booking; they apply instead of the statutory withdrawal right (C06.4).

3. Local tourist or accommodation taxes are shown separately and collected by the supplier unless the booking summary states otherwise.

4. The supplier's allergen, accessibility and house rules information is provided by the supplier; the Operator transmits it without alteration.

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Gustix International Transfer Schedule | Gustix