Privacy Policy

PRIVACY AND DATA PROTECTION POLICY
‍In accordance with current legislation, Suprey (hereinafter also referred to as the Website) commits to adopting the necessary technical and organizational measures according to the appropriate level of security risk for the collected data.
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Laws included in this privacy policy
This privacy policy is adapted to the current Spanish and European regulations concerning the protection of personal data on the internet. Specifically, it adheres to the following rules:
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The 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 on 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 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 Services of the Information Society and Electronic Commerce (LSSI-CE)

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Identity of the data controller
The controller of the personal data collected by Suprey is: Suprey Life S.L., provided with NIF/CIF: B13983911 and registered in: Madrid Mercantile Register.
The contact details are as follows:
Address: CALLE LAGASCA 24, MADRID 28001
Email: info@suprey.life

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Personal Data Registry
In compliance with the GDPR and the LOPD-GDD, we inform you that the personal data collected by Suprey through the forms extended on its pages will be incorporated and treated in our file in order to facilitate, expedite and fulfill the commitments established between Suprey and the User or the maintenance of the relationship that is established in the forms that he fills out or to attend a request or inquiry of the same. Additionally, in accordance with the provisions in the GDPR and the LOPD-GDD, unless the exception provided in Article 30.5 of the GDPR applies, a register of processing activities is maintained that specifies, according to its purposes, the processing activities carried out and the other circumstances established in the GDPR.

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Applicable principles to the processing of personal data
The processing of the User's personal data will be subject to the following principles listed in Article 5 of the GDPR and in Article 4 and subsequent articles 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 consent of the User is required at all times after completely transparent information of the purposes for which the personal data are collected.Principle of limitation of purpose: personal data will be collected for specific, explicit, and legitimate purposes.Principle of data minimization: the personal data collected will only be strictly necessary in relation to the purposes for which they are processed.Principle of accuracy: personal data must be accurate and always updated.Principle of limitation of the retention period: personal data will only be maintained in a way that allows the identification of the User for the necessary time for the purposes of their processing.Principle of integrity and confidentiality: personal data will be treated in such a way that their security and confidentiality are guaranteed.Principle of proactive responsibility: the Data Controller will be responsible for ensuring that the above principles are complied with.

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Categories of personal data
The categories of data that are processed in Suprey are only identification data. In no case are special categories of personal data processed in the sense of Article 9 of the GDPR.

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Legal basis for the processing of personal data
The legal basis for the processing of personal data is consent. Suprey commits to obtaining the express and verifiable consent of the User for the processing of his personal data for one or several specific purposes.
The User will have the right to withdraw his 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 condition the use of the Website.
On occasions in which the User must or may provide his data through forms to make inquiries, request information, or for reasons related to the content of the Website, he will be informed in the event that the completion of any of them is mandatory because they are essential for the proper development of the operation performed.

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Purposes of the processing to which the personal data are destined
Personal data is collected and managed by Suprey with the purpose of facilitating, expediting, and fulfilling the commitments established between the Website and the User or the maintenance of the relationship that is established in the forms that the latter fills out or to attend a request or inquiry.
Likewise, the data may be used with a commercial purpose of personalization, operational and statistical, and activities of the corporate purpose of Suprey, as well as for the extraction, storage of data and marketing studies to adapt the Content offered to the User, as well as improve the quality, operation, and navigation of the Website.
At the moment personal data are obtained, the User will be informed about the specific end or ends of the processing to which the personal data will be destined; that is, the use or uses that will be given to the information collected.

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Periods of retention 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 during the following term: 18 months or until the User requests its deletion.
At the moment the personal data are obtained, the User will be informed about the period during which the personal data will be preserved or, when that is not possible, the criteria used to determine this term.

Recipients of personal data
The personal data of the User will be shared with the following recipients or categories of recipients:
Google Analytics.
In case the Data Controller intends to transfer personal data to a third country or international organization, at the time the personal data are 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.

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Personal data of minors
Respecting 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 guarantee of digital rights, only those over 14 years old may grant their consent for the lawful processing of their personal data by Suprey. If it is a minor under 14 years old, the consent of the parents or tutors is necessary for the processing, and this will only be considered lawful to the extent that they have authorized it.

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Secrecy and security of personal data
Suprey commits to adopting the necessary technical and organizational measures according to the appropriate level of security to the risk of the data collected so that the security of the personal data is guaranteed and the destruction, loss, or accidental or unlawful alteration of personal data transmitted, stored or otherwise processed, or unauthorized communication or access to such data is avoided.
The Website has an SSL certificate (Secure Socket Layer) that ensures that personal data is transmitted securely and confidentially as the transmission of data between the server and the User, and in feedback, is totally encrypted or encrypted.
However, because Suprey cannot guarantee the impregnability of the internet nor the total absence of hackers or others who access personal data fraudulently, the Data Controller commits to communicate to the User without undue delay when a violation of the security of personal data that is likely to pose a high risk to the rights and freedoms of natural persons occurs. Following what is established in Article 4 of the GDPR, it is understood by violation of the security of personal data any violation of security that causes the destruction, loss, or accidental or unlawful 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 of and to 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

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Rights derived from the processing of personal data
The User has over Suprey and may, therefore, exercise against the Data Controller 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:
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Right of access: It is the right of the User to obtain confirmation of whether Suprey is treating his personal data and, if so, obtain information about his specific personal data and the treatment that Suprey has carried out or carries out, as well as, among other information, the available information about the origin of such data and the recipients of the communications made or planned of the same.

Right of rectification: It is the right of the User to modify his personal data that turn out to be inaccurate or, considering the purposes of the treatment, incomplete.

Right of suppression ("the right to be forgotten"): It is the right of the User, as long as the current legislation does not establish otherwise, to obtain the suppression of his personal data when these are no longer necessary for the purposes for which they were collected or treated; the User has withdrawn his consent to the treatment and this does not count on another legal basis; the User opposes the treatment and there is no other legitimate reason to continue with it; personal data have been unlawfully treated; personal data must be deleted in compliance with a legal obligation; or personal data have been obtained as a result of a direct offer of services of the information society to a minor under 14 years old.
In addition to deleting the data, the Data Controller, taking into account the available technology and the cost of its application, must take reasonable steps to inform the responsibles that are treating the personal data of the interested party's request for the deletion of any link to those personal data.
Right to limitation of treatment: It is the right of the User to limit the treatment of his personal data.
The User has the right to obtain the limitation of the treatment when he challenges the accuracy of his personal data; the treatment 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 treatment.
Right to the portability of the data: In case the treatment is carried out by automated means, the User will have the right to receive from the Data Controller his personal data in a structured format of common use and mechanical reading, and to transmit them to another data controller.
Whenever technically possible, the Data Controller will transmit the data directly to that other responsible.Right of opposition: It is the right of the User that the treatment of his personal data is not carried out or is ceased by Suprey.
Right not to be subject to a decision based solely on automated processing, including profiling: It is the right of the User not to be subject to an individualized decision based solely on automated processing of his personal data, including profiling, unless the current legislation establishes otherwise.
Therefore, the User may exercise his rights through written communication addressed to the Data Controller with the reference "GDPR-www.suprey.life", specifying:Name, surname of the User, and copy of the DNI.
In cases where representation is admitted, it will also be necessary to identify by the same means the person representing the User, as well as the document accrediting the representation.
The photocopy of the DNI may be replaced by any other valid means in law that accredits the identity.Request with the specific reasons of the request or information to which you want to access.Address for notification purposes.Date and signature of the applicant.Any document that accredits the request that is made.
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This request and any other attached document may be sent to the following address and/or email address:
Postal address: CALLE LAGASCA 24, MADRID 28001
Email: data@suprey.life

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Links to third party websites
The Website may include hyperlinks or links that allow access to web pages of third parties other than Suprey, and therefore are not operated by Suprey. 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.

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Claims before the control authority
In case the User considers that there is a problem or infringement of the current regulations in the way his personal data are being treated, he will have the right to effective judicial protection and to lodge a complaint with a control authority, in particular in the State where he has his habitual residence, place of work or place of the alleged infringement. In the case of Spain, the control authority is the Spanish Agency for Data Protection (https://www.aepd.es/).

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ACCEPTANCE AND CHANGES IN THIS PRIVACY POLICY
It is necessary that the User has read and is in agreement with the conditions on the protection of personal data contained in this Privacy Policy as well as that he accepts the treatment of his personal data so that the Data Controller can proceed with it in the form, during the terms and for the purposes indicated. The use of the Website will imply the acceptance of the Privacy Policy of the same.
Suprey 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 Agency for Data Protection. Changes or updates to this Privacy Policy will not be explicitly notified to the User. It is recommended to the User to consult this page periodically to be aware of the latest changes or updates.
This Privacy Policy was updated to adapt to the 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 on the free movement of such data (GDPR), and to Organic Law 3/2018 of December 5, on the Protection of Personal Data and guarantee of digital rights.k.