Respecting the provisions of current legislation, GROUPSUMI (hereinafter, also the Website) undertakes to adopt the necessary technical and organizational measures, according to the appropriate level of security for the risk of the collected data. Laws incorporated into this privacy policy This privacy policy is adapted to the current Spanish and European regulations on the protection of personal data on the internet. Specifically, it complies with the following rules: The Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, regarding the protection of individuals with regard to the processing of personal data and the free movement of such data (GDPR). Organic Law 3/2018, of December 5, on the Protection of Personal Data and 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 person responsible for the processing of personal data The person responsible for the processing of personal data collected in GROUPSUMI is TRUE-MAKERS, S.L., with NIF/CIF ESB67182725, registered in the Mercantile Registry of Barcelona and whose representative is True-makers, S.L. (hereinafter, the Data Controller). Your contact details are as follows: Address: Ronda General Mitre, 195-197 Barcelona, 08023 Contact email: [email protected]

In compliance with the GDPR and the LOPD-GDD, we inform you that the personal data collected by GROUPSUMI, through the forms extended on its pages, will be incorporated and processed in our file in order to facilitate, streamline and fulfill the commitments established between GROUPSUMI and the User or the maintenance of the relationship established in the forms filled out by the User, or to respond to a request or inquiry from the User. 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 kept specifying, according to their 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 following of Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights: Principle of lawfulness, fairness and transparency: the User's consent will always be required, preceded by completely transparent information about the purposes for which the personal data are collected. Principle of purpose limitation: personal data will be collected for specified, 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 always up to date. 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 such a way as to ensure 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 in GROUPSUMI are solely identifying data. Under no circumstances are special categories of personal data processed within the meaning 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. Withdrawing consent will be as easy as giving it. As a general rule, the withdrawal of consent will not affect the use of the Website.

In cases where the User must or may 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 carried out.

Purposes of the processing of personal data

Personal data is collected and managed by GROUPSUMI in order to facilitate, streamline, and fulfill the commitments established between the Website and the User or the maintenance of the relationship established in the forms filled out by the latter or to respond to a request or inquiry.

Likewise, the data may be used for commercial purposes of personalization, operation, and statistics, and activities related to the corporate purpose of GROUPSUMI, as well as for the extraction, storage of data, and marketing studies to adapt the Content offered to the User, as well as to improve the quality, functioning, and navigation of the Website.

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

Retention periods for 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 the personal data is obtained, the User will be informed about the period during which the personal data will be kept or, when this 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 the data is intended to be transferred, as well as the existence or absence of an adequacy decision by the Commission.

Personal data of minors

In compliance with the provisions of articles 8 of the GDPR and 7 of Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights, only individuals over 14 years of age may give their consent for the lawful processing of their personal data by GROUPSUMI. If the individual is under 14 years of age, the consent of their parents or legal guardians will be required for the processing, and it will only be considered lawful to the extent that they have authorized it.

Secrecy and security of personal data

GROUPSUMI is committed to adopting the necessary technical and organizational measures, according to the appropriate level of security for the risk of the collected data, in order to guarantee the security of personal data and prevent its destruction, loss, or accidental or unlawful alteration, or unauthorized communication or access to said data.

The Website has an SSL certificate (Secure Socket Layer), 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 fully encrypted.

However, since GROUPSUMI cannot guarantee the invulnerability of the internet or the total absence of hackers or others who fraudulently access personal data, the Data Controller undertakes to promptly inform the User when a security breach of personal data occurs that is likely to result in a high risk to the rights and freedoms of individuals. In accordance with Article 4 of the GDPR, a security breach of personal data is understood to be any breach of security that results in the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data transmitted, stored, or otherwise processed.

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

Rights derived from the processing of personal data

The User has the following rights recognized in the GDPR and Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights, and may therefore exercise them against GROUPSUMI:

• Right of access: It is the User's right to obtain confirmation as to whether or not GROUPSUMI is processing their personal data and, if so, to obtain information about their specific personal data and the processing that GROUPSUMI has carried out or is carrying out, as well as, among other things, information available on the origin of such data and the recipients of the communications made or planned for them.
• Right to rectification: It is the User's right to have their personal data modified if it is inaccurate or, taking into account the purposes of the processing, incomplete.
• Right to erasure ("right to be forgotten"): It is the User's right, provided that current legislation does not establish otherwise, to obtain the erasure of their personal data when it is no longer necessary for the purposes for which it was collected or processed; the User has withdrawn their consent to the processing and there is no other legal basis for the processing; the User objects to the processing and there are no overriding legitimate grounds for the processing; the personal data has been processed unlawfully; the personal data must be erased in compliance with a legal obligation; or the personal data has been obtained as a result of a direct offer of information society services to a child under 14 years of age. In addition to erasing the data, the Data Controller, taking into account the available technology and the cost of its implementation, must take reasonable measures to inform the controllers who are processing the personal data of the data subject's request to erase any link to that personal data.
• Right to restriction of 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 objected to the processing.
• Right to data portability: Where processing is carried out by automated means, the User has the right to receive their personal data from the Data Controller in a structured, commonly used, and machine-readable format, and to transmit it to another data controller. Where technically feasible, the Data Controller will transmit the data directly to that other controller. Right to object: It is the User's right to object to the processing of their personal data or to cease the processing of their personal data by GROUPSUMI.
• 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 automated processing of their personal data, including profiling, except as provided by current legislation.

Therefore, the User may exercise their rights by written communication addressed to the Data Controller with the reference "GDPR-www.groupsumi.es", specifying:

• Name, surname of the User, and a copy of the ID card. In cases where representation is admitted, the identification by the same means of the person representing the User will also be necessary, as well as the document accrediting the representation. The photocopy of the ID card may be substituted by any other valid means in law that proves the identity.
• Request with specific reasons for the request or information to which access is sought. Address for notifications.
• Date and signature of the applicant.
• Any document proving the request made.

This request and any other attached document may be sent to the following address and/or email:

Postal address: Ronda General Mitre, 195-197 Barcelona, 08023
Email: [email protected]

Links to third-party websites

The Website may include hyperlinks or links that allow access to third-party websites other than GROUPSUMI, and therefore not operated by GROUPSUMI. The owners of these websites will have their own data protection policies, being themselves, in each case, responsible for their own files and privacy practices.

Complaints to the supervisory authority

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

It is necessary for the User to have read and agree 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 implies acceptance of its Privacy Policy.

GROUPSUMI reserves the right to modify its Privacy Policy, according to its own criteria, or motivated by a legislative, jurisprudential or doctrinal change of the Spanish Data Protection Agency. 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 be aware of the latest changes or updates.

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