Privacy Policy
Updated on March 10, 2025

Privacy Policy and Data Protection

In accordance with current legislation, GROUPSUMI (hereinafter also referred to as the Website) commits to adopting the necessary technical and organizational measures, according to the level of security appropriate to the risk of the collected data.

Laws incorporated in this privacy policy

This privacy policy is adapted to the current Spanish and European regulations regarding the protection of personal data on the internet. Specifically, it complies with the following standards:
  • Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR).
  • Organic Law 3/2018, of December 5, on the Protection of Personal Data and the Guarantee of Digital Rights (LOPD-GDD).
  • Royal Decree 1720/2007, of December 21, which approves the Regulation for the development of Organic Law 15/1999, of December 13, on the Protection of Personal Data (RDLOPD).
  • Law 34/2002, of July 11, on Information Society Services and Electronic Commerce (LSSI-CE).

Identity of the data controller

The data controller of the personal data collected at GROUPSUMI is TRUE-MAKERS, S.L., with NIF/CIF ESB67182725, registered in the Barcelona Mercantile Registry and whose representative is True-makers, S.L. (hereinafter, Data Controller).

Your contact details are as follows:

Address: Ronda General Mitre, 195-197 Barcelona, 08023

Contact email: [email protected]

Personal Data Registration

In compliance with the provisions of the GDPR and the LOPD-GDD, we inform you that the personal data collected by GROUPSUMI through the forms provided on its pages will be incorporated and processed in our file in order to facilitate, expedite, and fulfill the commitments established between GROUPSUMI and the User or to maintain the relationship established in the forms they fill out, or to address a request or inquiry from them. Likewise, in accordance with the provisions of the GDPR and the LOPD-GDD, unless the exception provided for in Article 30.5 of the GDPR applies, a record of processing activities is maintained that specifies, according to its purposes, the processing activities carried out and the other circumstances established in the GDPR.

Principles applicable to the processing of personal data

The processing of the User's personal data will be subject to the following principles set out in Article 5 of the GDPR and in Article 4 and subsequent articles of Organic Law 3/2018, of December 5, on Personal Data Protection and the guarantee of digital rights:
  • Principle of lawfulness, loyalty, and transparency: the User's consent will be required at all times after completely transparent information about the purposes for which personal data is collected.
  • Principle of purpose limitation: personal data will be collected for determined, explicit, and legitimate purposes.
  • Principle of data minimization: the personal data collected will be only those strictly necessary in relation to the purposes for which they are processed.
  • Principle of accuracy: personal data must be accurate and kept up to date at all times.
  • Principle of storage limitation: personal data will only be kept in a way that allows the identification of the User for the time necessary for the purposes of its processing.
  • Principle of integrity and confidentiality: personal data will be processed in a manner that ensures its security and confidentiality.
  • Principle of proactive responsibility: the Data Controller will be responsible for ensuring that the above principles are complied with.

Categories of personal data

The categories of data processed by GROUPSUMI are solely identifying data. In no case are special categories of personal data processed in the sense of Article 9 of the GDPR.
The legal basis for the processing of personal data is consent. GROUPSUMI is committed to obtaining the express and verifiable consent of the User for the processing of their personal data for one or more specific purposes.

The User will have the right to withdraw their consent at any time. It will be as easy to withdraw consent as it is to give it. As a general rule, the withdrawal of consent will not affect the use of the Website.

In cases where the User must or can provide their data through forms to make inquiries, request information, or for reasons related to the content of the Website, they will be informed if the completion of any of them is mandatory because they are essential for the proper development of the operation being carried out.

Purposes of the processing to which personal data is intended

Personal data is collected and managed by GROUPSUMI in order to facilitate, expedite, and fulfill the commitments established between the Website and the User or to maintain the relationship established in the forms that the latter fills out or to address a request or inquiry.

Similarly, the data may be used for commercial purposes of personalization, operational and statistical purposes, and activities related to the corporate purpose of GROUPSUMI, as well as for data extraction, storage, and marketing studies to tailor the Content offered to the User, as well as to improve the quality, functionality, and navigation of the Website.

At the time personal data is obtained, the User will be informed about the specific purpose or purposes of the processing to which the personal data will be destined; that is, the use or uses that will be given to the collected information.

Retention periods of personal data

Personal data will only be retained for the minimum time necessary for the purposes of its processing and, in any case, only for the following period: 12 months, or until the User requests its deletion.

At the time personal data is obtained, the User will be informed about the period during which the personal data will be retained or, when that is not possible, the criteria used to determine this period.

Recipients of personal data

The User's personal data will be shared with the following recipients or categories of recipients:
  • Google
  • Google Analytics
  • Google Adwords
  • Facebook Ads
In the event that the Data Controller intends to transfer personal data to a third country or international organization, at the time the personal data is obtained, the User will be informed about the third country or international organization to which it is intended to transfer the data, as well as the existence or absence of an adequacy decision by the Commission.

Personal data of minors

In accordance with the provisions of Article 8 of the GDPR and Article 7 of Organic Law 3/2018, of December 5, on the Protection of Personal Data and the guarantee of digital rights, only those over 14 years old may give their consent for the lawful processing of their personal data by GROUPSUMI. If it concerns a minor under 14 years of age, parental or guardian consent will be required for processing, and this will only be considered lawful to the extent that they have authorized it.

Privacy and security of personal data

GROUPSUMI is committed to adopting the necessary technical and organizational measures, according to the level of security appropriate to the risk of the collected data, in such a way that the security of personal data is guaranteed and the accidental or unlawful destruction, loss, or alteration of personal data transmitted, stored, or otherwise processed, or the unauthorized communication or access to such data is prevented.

The Website has an SSL (Secure Socket Layer) certificate, which ensures that personal data is transmitted securely and confidentially, as the transmission of data between the server and the User, and in feedback, is completely encrypted.

However, since GROUPSUMI cannot guarantee the invulnerability of the internet or the complete absence of hackers or others who may fraudulently access personal data, the Data Controller commits to inform the User without undue delay when a personal data security breach occurs that is likely to result in a high risk to the rights and freedoms of individuals. Following the provisions of Article 4 of the GDPR, a personal data security breach is understood to be any breach of security that results in the accidental or unlawful destruction, loss, or alteration of personal data transmitted, stored, or otherwise processed, or the unauthorized communication or access to such data.

Personal data will be treated as confidential by the Data Controller, who commits to inform and ensure through a legal or contractual obligation that such confidentiality is respected by its employees, associates, and any person to whom the information is made accessible.

Rights derived from the processing of personal data

The User has rights over GROUPSUMI and may, therefore, exercise the following rights recognized in the GDPR and Organic Law 3/2018, of December 5, on Personal Data Protection and the guarantee of digital rights against the Data Controller:
  • Right of access: It is the User's right to obtain confirmation of whether GROUPSUMI is processing their personal data or not and, if so, to obtain information about their specific personal data and the processing that GROUPSUMI has carried out or will carry out, as well as, among other things, information available about the source of such data and the recipients of the communications made or planned regarding them.
  • Right of rectification: It is the User's right to have their personal data modified if they are found to be inaccurate or, taking into account the purposes of the processing, incomplete.
  • Right of deletion ("the right to be forgotten") : It is the User's right, unless otherwise provided by current legislation, to obtain the deletion of their personal data when they are no longer necessary for the purposes for which they were collected or processed; the User has withdrawn their consent to the processing and there is no other legal basis for it; the User opposes the processing and there is no other legitimate reason to continue; the personal data has been processed unlawfully; the personal data must be deleted to comply with a legal obligation; or the personal data has been obtained as a result of a direct offer of information society services to a minor under 14 years of age. In addition to deleting the data, the Data Controller, taking into account the available technology and the cost of its application, must take reasonable measures to inform those responsible for processing the personal data of the request for deletion of any link to that personal data.
  • Right to restrict processing: It is the User's right to restrict the processing of their personal data. The User has the right to obtain the restriction of processing when they contest the accuracy of their personal data; the processing is unlawful; the Data Controller no longer needs the personal data, but the User needs it to make claims; and when the User has opposed the processing.
  • Right to data portability: In the event that the processing is carried out by automated means, the User will have the right to receive from the Data Controller their personal data in a structured, commonly used, and machine-readable format, and to transmit it to another data controller. Whenever technically feasible, the Data Controller will directly transmit the data to that other controller. Right to object: It is the User's right that the processing of their personal data is not carried out or that the processing of the same by GROUPSUMI is ceased.
  • Right not to be subject to a decision based solely on automated processing, including profiling: It is the User's right not to be subject to an individualized decision based solely on the automated processing of their personal data, including profiling, unless current legislation provides otherwise.
Thus, the User may exercise their rights by sending a written communication to the Data Controller with the reference "GDPR-groupsumi.ie", specifying:
  • Name, surname of the User and a copy of the ID. In cases where representation is allowed, the identification of the person representing the User by the same means will also be necessary, as well as the document proving the representation. The photocopy of the ID may be replaced by any other legally valid means that proves identity.
  • Request with the specific reasons for the request or information to which access is sought. Address for notification purposes.
  • Date and signature of the applicant.
  • Any document that proves the request being made.
This request and any other attached document can be sent to the following address and/or email:

Postal address: Ronda General Mitre, 195-197 Barcelona, 08023
The Website may include hyperlinks or links that allow access to third-party web pages other than GROUPSUMI, and which are therefore not operated by GROUPSUMI. The owners of such websites will have their own data protection policies, being themselves, in each case, responsible for their own files and their own privacy practices.

Claims before the supervisory authority

If the User believes that there is a problem or violation of current regulations regarding the way their personal data is being processed, they have the right to effective judicial protection and to file a complaint with a supervisory authority, particularly in the country where they have their habitual residence, place of work, or where the alleged infringement occurred. In the case of Spain, the supervisory authority is the Spanish Agency for Data Protection.

Acceptance and changes to this privacy policy

It is necessary for the User to have read and agreed to the conditions regarding the protection of personal data contained in this Privacy Policy, as well as to accept the processing of their personal data so that the Data Controller can proceed with it in the manner, for the periods, and for the purposes indicated. The use of the Website will imply acceptance of its Privacy Policy.

GROUPSUMI reserves the right to modify its Privacy Policy, at its own discretion, or due to a legislative, jurisprudential, or doctrinal change from the Spanish Agency for Data Protection. Changes or updates to this Privacy Policy will not be explicitly notified to the User. It is recommended that the User consult this page periodically to stay informed of the latest changes or updates.

This Privacy Policy has been updated to comply with Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR) and with Organic Law 3/2018, of December 5, on the Protection of Personal Data and the guarantee of digital rights.
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