Privacy Policy

DATA CONTROLLER

The data controller is SERMOS 32, S.L., with Tax Identification Code B84211176 and registered office at calle de Alcalá, 73, piso 7, puerta A, postal code 28009, Madrid. It is registered with the Business Registry of Madrid in volume 20,881, book 0, Folio 52, Section 8, Sheet M-370175, entry 1.

The contact details of the data controller are:

Post address: Calle Alcalá, 73, 7ºA, 28009. Madrid

Email: [email protected] 

WHAT KIND OF PERSONAL DATA DO WE PROCESS?

Depending on the services or functionalities of this website that you are using, or the reason for contacting us, we may request and process different types of personal data from you. In any case, we will only record and process the data that are essential for each purpose, and always within the following categories:

Identifying data: such as your name, surname, contact details..

IP address and other possible data associated with your session, browsing, device or similar.

PURPOSES OF THE PROCESSING

The purposes of the data processing carried out by SERMOS 32, S.L. shall be:

  • To record accesses and browsing sessions on the website in order to optimise its operation and improve the user experience, as specified in the Cookies Policy.

This purpose will include, among other activities, analysing the usability of the website and certain aspects of user browsing, pre-configuring functionalities or characteristics of the site to adapt them to the data recorded, carrying out statistical and metric analyses, and other similar activities that will always comply with the provisions of this Privacy Policy, as well as the Cookies Policy:

  • To manage contact requests and commercial and other proposals received through the website.

This purpose will include, among other activities, receiving, analysing and responding to requests, as well as managing the tasks that may arise from them.

  • To manage the awarding of prizes corresponding to draws, competitions and other participatory events organised by Sergio Ramos on his official channels.

This purpose will include contact with the winner or winners and the management of the delivery or effective enjoyment by them of the prize in question, as well as the management of incidents and other issues that may arise.

  • To communicate the relevant data requested, where appropriate, by the competent authorities in accordance with the law.

In this case, SERMOS 32, S.L. will only verify the existence of the legal duty that gives rise to the request.

LEGITIMISATION OF PROCESSING

SERMOS 32, S.L. considers it relevant to inform users that we are obliged to justify why we process their personal data and our legitimisation to do so. According to the same scheme as above, for clarity and transparency:

  • To record accesses and browsing sessions on the website in order to optimise its operation and improve the user experience, as specified in the Cookies Policy.

In this case, we understand that, as the data controller, we have a legitimate interest in carrying out the processing, to optimise and adapt our web channel, and to configure certain aspects of the browsing and/or user experience of our current and potential customers. As is mandatory in relation to this basis of legitimisation provided for in article 6.1.f) of the GDPR, we have carried out the corresponding weighing judgement, and we understand that, as owners of the website, we have the right to analyse data relating to the traffic and operation of the website, and, at the same time, we consider that this analysis is of benefit to the user, by providing them with a better browsing and experience.

  • To manage contact requests and commercial and other proposals received through the website.

For this second purpose, we understand that we have a legitimate interest in processing your data to resolve these issues. In addition, and proceeding on the balancing test that we are obliged to perform when invoking this basis of standing, we believe that your rights and user experience are better protected. The GDPR provides for this basis of legitimacy in Article 6(1)(f).

  • To manage the awarding of prizes corresponding to draws, competitions and other participatory events organised by Sergio Ramos on his official channels.

For this purpose, the legitimacy to process your data derives from your own consent, which you have given us by providing us with the data for this purpose and by accepting the legal bases of the action in which the relevant privacy issues are specified. This basis of legitimacy is provided for in Article 6(1)(a) of the GDPR.

  • To communicate the relevant data requested, where appropriate, by the competent authorities in accordance with the law.

In this case, standing is clear and derives from the duty to comply with a legal obligation. This basis of legitimacy is provided for in Article 6(1)(c) of the GDPR.

RECIPIENTS OF THE DATA

SERMOS 32, S.L. will not share the personal data of users, except with those third parties who must intervene in any of the essential processes to provide the requested service or to keep the website operational and in good condition. For example, it may transfer data to web providers for server or security purposes. In this case, the data controller assumes the obligation to require these third parties to implement the same security measures applied by SERMOS 32, S.L., or other similar measures adapted to the same level of data security.

SERMOS 32, S.L. may also transfer data to third parties in order to comply with a legal obligation, if required to do so by a legitimate and competent authority.

STORAGE OF DATA

Once again, and for greater clarity and transparency, SERMOS 32, S.L. provides users with the information corresponding to the data retention periods following the same scheme as above, based on the purposes of the processing:

  • To record accesses and browsing sessions on the website in order to optimise its operation and improve the user experience, as specified in the Cookies Policy.

SERMOS 32, S.L. will only keep the data for as long as the corresponding measurement or website configuration actions are in progress.

  • To manage contact requests and commercial and other proposals received through the website.

SERMOS 32, S.L. will keep the data for as long as the contacts or actions in progress remain in progress, and until the civil, contractual or similar actions contemplated by law, arising from the possible relationship or contact established, expire.

  • To manage the awarding of prizes corresponding to draws, competitions and other participatory events organised by Sergio Ramos on his official channels.

SERMOS 32, S.L. will keep the data until the interested party revokes the consent given or, in any case, until the expiry of the statute of limitations for civil, contractual or similar actions contemplated by law, arising from the prize draw, competition or dynamic.

  • To communicate the relevant data requested, where appropriate, by the competent authorities in accordance with the law.

SERMOS 32, S.L. will keep the data until the civil, contractual or similar actions contemplated by law, which could give rise to the legal requirement or obligation that legitimises the communication or transfer, expire.

RIGHTS OF THE HOLDERS

The holders of the data processed may exercise their rights of access, rectification, oblivion or deletion, cancellation, portability, limitation of processing and other rights recognised by current legislation by sending an e-mail to the following address [email protected]

In any case, the data subjects may contact the competent authority in Spain, the Spanish Data Protection Agency, for any queries or procedures www.aepd.es

AMENDMENTS TO THIS PRIVACY POLICY

SERMOS 32, S.L. has defined this Privacy Policy in an exhaustive manner, but it may need to be modified in the future, due to a change in the applicable legislation or in the recommendations and rulings of the Spanish Data Protection Agency (AEPD), due to the introduction of new functionalities or services on the website, or for any other reason.

In that case, we will notify you in a visible, clear and specific manner on the website and, if the change particularly affects your privacy or the way we process your personal data, we will send you an email or contact you through another available channel, requesting your consent, if necessary.

In any case, SERMOS 32, S.L. advises users to review this Privacy Policy, as well as the Legal Notice and the Cookies Policy of the website, from time to time.

This version of the Privacy Policy has been drawn up in Madrid, Spain, on the 9th of November 2021.