Data Protection Policy

SA DE PRODUCTOS ELECTRONICOS Y DE COMUNICACIÓN S.A Data Protection Policy

1. Who is the Controller of your data?

The Controller responsible for the processing of the data related to the different processes involved in the management of our users is SA DE PRODUCTOS ELECTRONICOS Y DE COMUNICACIÓN S.A , with registered office in C/ RUFINO GONZALEZ 15 28037 MADRID and CIF A28422244 .

For the purposes of our data protection policy, the contact telephone number is +34917283910 and the contact email sapec@sapec.es.

2. What kind of data do we have about you and how did we obtained them?

The personal data categories that SA DE PRODUCTOS ELECTRONICOS Y DE COMUNICACIÓN S.A processes about its customers and providers include:

Identification data
Postal or electronic addresses
Business information
Financial and transactional data
Add further categories as appropriate

Under no circumstances we process sensitive data.

We have obtained all the above data either directly from you by sending a contact form or submitting a contractual proposal, commercial tender, etc., or through your company when they provided us with identification details and other data needed to carry out the purpose of the contractual relationship between the parties. You or your company will be responsible for providing us with current data in case of any change.

3. With what purpose do we process your data?

At SA DE PRODUCTOS ELECTRONICOS Y DE COMUNICACIÓN S.A, we process the data made available to us by the persons concerned (data subjects) with the purpose of managing different activities associated to specific procedures related to sales, aftersales services, vendor management, service quality assurance, etc. Thus, we will use your data to carry out some of the following actions:

Submitting the information we are requested to provide via the contact form of our web site or any other means of contact with our company,
Providing our customers or prospects with proposals about products or services which may be of interest to them,
Handling the administrative, tax and accounting management tasks linked to our customers and/or vendors,
Conducting satisfaction surveys, market research, etc., in order to be able to bring you the most suitable offers, optimise our quality of service, etc.

We do not conduct commercial profiling based on the information provided, therefore we will not take automated decisions about you based on a commercial profile.

4. For how long will we retain your data?

The personal data associated to individuals linked to customers, prospects and suppliers which SA DE PRODUCTOS ELECTRONICOS Y DE COMUNICACIÓN S.A collects through the different contact and data gathering forms will be retained for as long as their removal is not requested by the person concerned. The data provided by our customers and vendors will be retained for as long as the business relationship between the parties continues to exist, always observing the minimum legal data retention periods established by law according to the case

In any event, SA DE PRODUCTOS ELECTRONICOS Y DE COMUNICACIÓN S.A will keep your personal data for the period of time as may be reasonably necessary to meet our needs of answering any questions raised, fixing problems, implementing improvements, activating new services and fulfilling the requirements set by the applicable regulation. This means that we may retain your personal data for a reasonable period of time even when you are no longer using our products or you have stopped using our website. After that period, your personal data will be removed from all the systems operated by SA DE PRODUCTOS ELECTRONICOS Y DE COMUNICACIÓN S.A

5. What is the legitimate interest for processing your data?

According to the data processing type, we will summarise below the legitimate interest of such processing:

PROCESSING TYPE	LEGITIMATE INTEREST
Accounting management: invoicing management with customers and/or suppliers	Maintaining, developing and controlling the contractual relationship between the parties
Tax management: application of tax withholdings, credits, etc.	Maintaining, developing and controlling the contractual relationship between the parties; fulfilment of legal obligations
Administrative management: management of logistics, warehouse, customer deliveries, goods receipt, etc.	Maintaining, developing and controlling the contractual relationship between the parties;
Marketing: sales actions about our products or services, addressed to our customers or to people who had requested us information in the past, including satisfaction surveys among our customers.	Free and unambiguous consent from the person concerned (prospects), pointing out to that person that the withdrawal of such consent may in no case condition the performance of any contract between the parties; legitimate interest of the company for the marketing and promotion of products or services similar to those obtained or requested by the persons concerned in the past.

As regards the above legitimate interests, You must provide your personal details, otherwise it will not be possible to perform the contract and fulfil the obligations established by law or from the public authorities.

6. Which recipients will your data be shared with?

SA DE PRODUCTOS ELECTRONICOS Y DE COMUNICACIÓN S.A will never share your personal data with any third-party company intending to use them for their direct marketing actions, unless you have expressly authorised us to do so.

Please note that we may deliver your personal data to Public Administration bodies and legal authorities concerned in such cases where SA DE PRODUCTOS ELECTRONICOS Y DE COMUNICACIÓN S.A is legally requested to provide them by such authorities, or if we consider in good faith that such action is reasonably necessary to comply with a court proceeding; to reply to any judicial or legal claim; or to protect the rights of SA DE PRODUCTOS ELECTRONICOS Y DE COMUNICACIÓN S.A, its customers, or the public at large.

All our companies are based in Spain.

SA DE PRODUCTOS ELECTRONICOS Y DE COMUNICACIÓN S.A can provide your personal data to third parties (i.e., internet service providers helping us to manage our web site or carry out the contracted services, IT support and maintenance providers, logistic partners, processing agencies, tax and accounting advisors, etc.). In any case, such third parties must always maintain the same protection level as SA DE PRODUCTOS ELECTRONICOS Y DE COMUNICACIÓN S.A in connection with your personal data, and will be bound, as necessary, by legal commitments to keep your personal data private and safe and use the information only as specifically instructed by SA DE PRODUCTOS ELECTRONICOS Y DE COMUNICACIÓN S.A.

7. What are your rights as the data subject or person concerned?

Any person has a right to obtain confirmation about whether or not SA DE PRODUCTOS ELECTRONICOS Y DE COMUNICACIÓN S.A is processing personal data of his or her concern.

Specifically, those concerned may request the right of access to their personal data, and receive their data in a common format, that must be machine-readable if the data processing is to be carried out through electronic means (data portability right).

Also, the persons concerned may request the right of rectification of any inaccurate data or, as appropriate, ask them to be deleted when, among other reasons, such data are no longer required for the purposes they were initially collected.

Additionally, in some specific circumstances, the persons concerned may request the limitation of processing of their data, or, in some cases and for reasons related to their particular situation, enforce their right of objection to the processing of their data. In such cases, SA DE PRODUCTOS ELECTRONICOS Y DE COMUNICACIÓN S.A will cease to process the data, except for legitimate compelling reasons, or to initiate or defend against eventual legal claims, or in the exceptional conditions provided for in the applicable regulation.

We also advise you that you are entitled to withdraw at any time the consent granted, without such withdrawal affecting the legitimacy of the processing we may have carried out before based on your previous consent.

We also inform the User that he or she may exercise at any time said rights by serving written notice to us using the contact data provided in Paragraph 1, ‘Data Controller’ of this SA DE PRODUCTOS ELECTRONICOS Y DE COMUNICACIÓN S.A, Data Protection and Privacy Policy, attaching a copy of your DNI (Spanish ID card). You will also be entitled to file a complaint with the Spanish Data Protection Agency (AEPD), especially when you have not been able to satisfactorily exercise your rights.

Agencia Española de Protección de Datos. C/ Jorge Juan, 6
28001 – Madrid
Phone 901100099 / 912663517

8. Website users’ data protection.

According to the current Regulation (UE) 2016/679, SA DE PRODUCTOS ELECTRONICOS Y DE COMUNICACIÓN S.A advises that the personal data linked to the users of the website will be processed by SA DE PRODUCTOS ELECTRONICOS Y DE COMUNICACIÓN S.A for the purposes indicated in each data collection form available in our web site. Such data treatment will be based on your own consent. By clicking on the “ENVIAR” (Submit) button, the User consents to the processing of his or her data by SA DE PRODUCTOS ELECTRONICOS Y DE COMUNICACIÓN S.A.

We also inform you that, unless otherwise required by law or you expressly consent to, SA DE PRODUCTOS ELECTRONICOS Y DE COMUNICACIÓN S.A will not transfer your data to third parties. (In case they are transferred, you will be informed about what data will be transferred and to whom)

We also advise that the User can exercise at any time the rights of access, rectification or deletion of the data, as well as other rights acknowledge hereunder and stipulated in Regulation (UE) 2016/679, by notifying it to SA DE PRODUCTOS ELECTRONICOS Y DE COMUNICACIÓN S.A, C/ RUFINO GONZALEZ 15 28037 MADRID (province of MADRID), e-mail: sapec@sapec.es.On the other hand, pursuant to the provisions of Law 34/2002, dated 11 July, on Information Society Services and E-Commerce, SA DE PRODUCTOS ELECTRONICOS Y DE COMUNICACIÓN S.A undertakes not to send any advertising via email without first obtaining the express consent from the recipient. The User may oppose to receiving advertising by clicking the relevant checkbox.

9. Other information of interest about our privacy policy

9.1 Security measures

SA DE PRODUCTOS ELECTRONICOS Y DE COMUNICACIÓN S.A adopts the security levels required by the Spanish and European data protection regulation taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of the processing as described, as well as the risks to their personal rights and freedoms, of variable likelihood and severity.

9.2 Processing of data concerning minors

Pursuant to EU 679/2016 GDPR and RD 1720/2007, minors over the age of 14 may give their consent to engaging into information society services, such as registration in a message forum, filling out a contact form, etc. However, SA DE PRODUCTOS ELECTRONICOS Y DE COMUNICACIÓN S.A will be responsible for verifying the age indicated by the minor.
The processing of data concerning minors under the age of 14 will always require the express consent of their parents or legal guardians.

9.3 Changes to our Privacy and Data Protection Policy

Occasionally, SA DE PRODUCTOS ELECTRONICOS Y DE COMUNICACIÓN S.A may make changes and amendments to this Data Protection Policy section for Users, customers and suppliers. Please check this section on a regular basis to find out eventual changes and how they may impact you.

9.4 Why is this Data Protection and Privacy Policy necessary?

This Data Protection Policy section for Users, customers and suppliers provides you, in an easily readable format, all the information required to identify the kind of data the SA DE PRODUCTOS ELECTRONICOS Y DE COMUNICACIÓN S.A holds about its customers, prospects and/or suppliers, the intended purposes, the rights the data protection regulation grants to you as the person concerned (data subject) and how can these rights be exercised. Therefore, by deliberately sending your personal data through our means of contact and/or starting your business relationship with our company, we understand that you acknowledge and consent to the processing of your personal data as described in this policy. This personal information will only be used for the purposes for which you have provided it to us, or for which we are allowed by specific national or regional regulations.

In any case, we must warn you that your refusal to furnish some of the requested data to us could hinder the performance of the contractual relationship between the parties, with possibly adverse consequences when the time comes to deliver the different services provided for in the contract entered into with the other party.

If you have any question regarding this SA DE PRODUCTOS ELECTRONICOS Y DE COMUNICACIÓN S.A Data Protection Policy for Customers, Prospects and Suppliers, please contact our company through the address indicated in paragraph 1 “Data Controller”. We will be pleased to help you and answer any additional question you may rise.

10. Applicable law

These Conditions will always be governed by the Spanish and European regulation on privacy and personal data protection.