https://suwmus.com

I. PRIVACY AND DATA PROTECTION POLICY
In compliance with current legislation, Suwmus (hereinafter also the Website) undertakes to adopt the necessary technical and organisational measures, according to the level of security appropriate to the risk of the data collected.

Laws that this privacy policy incorporates
This privacy policy is adapted to current Spanish and European regulations on the protection of personal data on the Internet. Specifically, it complies with the following regulations:

• Regulation (EU) 2016/679 of the European Parliament and of the Council, of 27 April 2016, on the protection of natural persons with regard to the processing of personal data and the free circulation of such data (RGPD).
• Organic Law 3/2018, of 5 December, on the Protection of Personal Data and Guarantee of Digital Rights (LOPD-GDD).
• Royal Decree 1720/2007, of December 21, approving the Regulations 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 processing personal data
Address: Office 109 Deyyar Building, Al Barsha 1

Contact phone number: +971 559 965 605

Contact email: management@suwmus.com

Personal Data Record
In compliance with the provisions of the GDPR and the LOPD-GDD, we inform you that the personal data collected by Suwmus, through the forms on its pages, will be incorporated and processed in our file in order to facilitate, expedite and fulfill the commitments established between Suwmus and the User or the maintenance of the relationship established in the forms that the User fills out, or to respond to a request or query 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 is applicable, a record of processing activities is kept that specifies, 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 legality, loyalty and transparency: the User’s consent will be required at all times after completely transparent information on the purposes for which the personal data is collected.
• Principle of limitation of purpose: personal data will be collected for specific, explicit and legitimate purposes.
• Principle of data minimisation: only the personal data collected will be 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 limitation of the retention period: personal data will only be kept in a way that allows the identification of the User for the time necessary for the purposes of their processing.
• Principle of integrity and confidentiality: personal data will be processed in a way that guarantees their security and confidentiality.
• Principle of proactive responsibility: the Data Controller will be responsible for ensuring that the above principles are met.
  

Categories of personal data
The categories of data processed by Suwmus are only identifying data. In no case are special categories of personal data processed within the meaning of article 9 of the GDPR.

Legal basis for the processing of personal data
The legal basis for the processing of personal data is consent. Suwmus undertakes to obtain the express and verifiable consent of the User for the processing of their personal data for one or more specific purposes.

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

On occasions when the User must or may provide their data through forms to make enquiries, 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 correct development of the operation carried out.

Purposes of the processing for which personal data are intended
Personal data is collected and managed by Suwmus in order to facilitate, expedite and fulfil 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 respond to a request or enquiry.

Likewise, the data may be used for commercial purposes of personalisation, operation and statistics, and activities inherent to the corporate purpose of Suwmus, 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, operation and navigation of the Website.

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

Personal data retention periods
The 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: 24 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 that is not possible, the criteria used to determine this period.

Recipients of personal data
The User’s personal data will not be shared with third parties.

In any case, at the time the personal data is obtained, the User will be informed about the recipients or categories of recipients of the personal data.

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 the Guarantee of Digital Rights, only those over 14 years of age may give their consent for the lawful processing of their personal data by Suwmus. If the minor is under 14 years of age, the consent of the parents or guardians will be required for the processing, and this will only be considered lawful to the extent that they have authorized it.

Confidentiality and security of personal data
Suwmus undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected, in order to guarantee the security of personal data and to prevent accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or unauthorized communication or access to said data.

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 fully encrypted.

However, since Suwmus cannot guarantee the impregnability of the Internet or the total absence of hackers or others who fraudulently access personal data, the Data Controller undertakes to inform the User without undue delay when a breach of the security of personal data occurs that is likely to entail a high risk for the rights and freedoms of natural persons. Pursuant to the provisions of Article 4 of the GDPR, a breach of the security of personal data is understood to mean any breach of security that leads to 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 undertakes to inform and guarantee by means of a legal or contractual obligation that said 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 over Suwmus and may, therefore, exercise 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 against the Data Controller:

• Right of access: It is the User’s right to obtain confirmation of whether or not Suwmus is processing their personal data and, if so, to obtain information about their specific personal data and the processing that Suwmus has carried out or is carrying out, as well as, among others, the information available on the origin of said data and the recipients of the communications made or planned for them.
• Right of rectification: It is the User’s right to have their personal data modified if it turns out to be inaccurate or, taking into account the purposes of the processing, incomplete.
• Right to erasure («the right to be forgotten»): This is the right of the User, unless the current legislation establishes otherwise, to obtain the deletion of his/her personal data when these are no longer necessary for the purposes for which they were collected or processed; the User has withdrawn his/her consent to the processing and there is no other legal basis for this; the User opposes the processing and there is no other legitimate reason to continue with it; the personal data have been processed unlawfully; the personal data must be deleted in compliance with a legal obligation; or the personal data have 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 adopt reasonable measures to inform the controllers who are processing the personal data of the interested party’s request to delete any link to said personal data.
• Right to limitation of processing: This is the User’s right to limit the processing of his/her personal data. The User has the right to obtain limitation of processing when he or she contests the accuracy of his or her 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: In the event that the processing is carried out by automated means, the User shall have the right to receive from the Data Controller his or her personal data in a structured, commonly used and machine-readable format, and to transmit it to another data controller. Whenever technically possible, the Data Controller will directly transmit the data to that other controller.
• Right to object: This is the User’s right to prevent the processing of his or her personal data or to stop the processing of the same by Suwmus.

Right not to be subject to a decision based solely on automated processing, including profiling: This is the User’s right not to be subject to an individualised decision based solely on the automated processing of their personal data, including profiling, unless otherwise provided by current legislation.
Thus, the User may exercise their rights by means of written communication addressed to the Data Controller with the reference «RGPD-https://suwmus.com», specifying:

• Name, surname of the User and copy of the ID. In cases where representation is admitted, 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 may be replaced by any other legally valid means that accredits the 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 accredits the request made.

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

Postal address: Office 109 Deyyar Building, Al Barsha 1

Email: management@suwmus.com

Links to third party websites
The Website may include hyperlinks or links that allow access to websites of third parties other than Suwmus, and which are therefore not operated by Suwmus. The owners of said websites will have their own data protection policies, and they themselves will be responsible, in each case, for their own files and their own privacy practices.

Claims before the supervisory authority
In the event that the User considers that there is a problem or infringement of current regulations in the way in which their personal data is being processed, they will have the right to effective judicial protection and to file a claim before a supervisory authority, in particular, in the State in which they have their habitual residence, place of work or place of the alleged infringement. In the case of Spain, the supervisory authority is the Spanish Data Protection Agency (http://www.agpd.es).

II. ACCEPTANCE AND CHANGES IN THIS PRIVACY POLICY
It is necessary that the User has read and agrees with the conditions on the protection of personal data contained in this Privacy Policy, as well as accept the processing of their personal data so that the Data Controller can proceed with it in the manner, during the periods and for the purposes indicated. The use of the Website will imply the acceptance of the Privacy Policy of the same.

Suwmus reserves the right to modify its Privacy Policy, at its own discretion, 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. The User is recommended to consult this page periodically to be aware of the latest changes or updates.

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

This Privacy Policy document for a website has been created using the online privacy policy template generator on 01/07/2021.