PRIVACY POLICY AND LEGAL NOTICE

 

Privacy Policy

At Summa we work to offer you the best possible experience through our products and services. In some cases, data needs to be collected to achieve this. We care about your privacy and believe we should be transparent in this regard.

For this reason, and pursuant to the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council, of 27 April 2016 (hereinafter, “GDPR”), on the protection of individuals with regard to the processing of their personal data and the free movement of such data, and Law 34/2002, of 11 July, on information society services and e-commerce (hereinafter, “LSSI”), Summa informs the user that, as the data controller, it will incorporate the personal data provided into an automated file.

 

Our commitment begins with the following explanation:

Your data are collected to enhance your user experience according to your interests and needs.

We are transparent about what data we collect about you and why.

Our intention is to provide you with the best possible experience. Accordingly, whenever we use your personal information, we will always do so within the confines of the law and, when necessary, we will ask for your consent.

We understand that your data belong to you. Therefore, if you decide not to authorise the processing of your data, you can ask us to cease processing your data.

Our priority is to ensure your security and to process your data in accordance with European regulations.

 

Who is the data controller responsible for processing your personal data?

Identity

Summa Comunicació, S.A.(Summa)

A58933581

Calle Badajoz 127, naves 3-4, Barcelona (Spain)

+34 932 081 090

barcelona@summa.es

Barcelona Companies Register T 10813, L 9765, S 2, F 210, H 125239, I 1, 21/07/1

 

What personal data do we collect?

Personal data the user may be asked to provide:

– Name

– Telephone number and email address.

– Your IP address, the date and time you accessed our services, the browser you use, and data related to the operating system installed on your device.

– Any other information or data you decide to share with us.

In some cases, registration is a requirement for accessing and enjoying some of the services offered on the website; thus, refusal to provide the personal data requested or consent to this data protection policy will make it impossible to subscribe to, register or participate in any of the promotions in which personal data are requested.

 

Why and for what purpose do we process your data?

Summa processes the information provided by interested parties for the following purposes:

– To send information requested by the user.

– To carry out commercial activities and maintain and manage the relationship with the user, as well as manage services offered via the website and carry out data tasks, including automated assessments and customer profiling and segmentation tasks, for the purpose of customising the service to individual characteristics and needs and enhancing the user’s online experience.En algunos casos será necesario facilitar información a las Autoridades o terceras empresas por motivos de auditoría, así como manejar datos personales de facturas, contratos y documentos para responder a reclamaciones de clientes o de las Administraciones Públicas

You are advised that the personal data obtained as a result of your registration as a user will be recorded on the Register of Processing Activities and Operations (RAT), which will be updated periodically in accordance with the provisions of the GDPR.

 

What is the legal basis for the processing of your data?

The following legal grounds are the basis for the processing of your data:

– Consent of the data subject to product and services provision agreements, contact forms, requests for information or subscription to e-newsletters.

– Legitimate interest in the processing of our customers’ data in direct marketing actions and express consent of the data subject in all matters relating to automated assessments and profiling.

– Compliance with legal obligations for fraud prevention, communication with public authorities and third-party claims.

 

How long do we store your data for?

The processing of the data for the purposes described will be maintained for as long as necessary to fulfil the purpose for which the data was collected (e.g. the duration of the commercial relationship), as well as to fulfil any legal obligations arising therefrom.

 

Which third parties does Summa communicate your data to?

In certain cases, only when necessary, Summa will provide third parties with user data. However, this data will never be sold to third parties. The external service providers Summa works with may use the data to provide the corresponding services; they may not, however, use this information for their own purposes or for transfer to third parties.

Summa endeavours to guarantee the security of personal data sent outside the company and ensures that third-party service providers respect confidentiality and have appropriate measures in place to protect our users’ personal data. These third parties are bound to ensure that the data they receive is processed in accordance with data privacy regulations.

In certain cases, the law may require that personal data be disclosed to public bodies or other parties, but only the data strictly necessary for the fulfilment of such legal obligations will be disclosed.

 

Where is your data stored?

As a general rule, your data is stored within the EU.

 

What rights do you have and how can you exercise them?

You can address your communications and exercise your rights by sending a request to the following e-mail address:  barcelona@summa.es

Under the provisions of the GDPR, you may exercise the following rights:

– Right of access: you can request information regarding the personal data we hold on you.

– Right to rectification: you can communicate any changes to your personal data.

– Right to erasure and to be forgotten: you can ask for your personal data to be blocked and subsequently erased.

– Right to restriction of processing: you can restrict the extent to which your data is processed.- Derecho de oposición: puedes retirar el consentimiento del tratamiento de los datos, oponiéndose a que se sigan tratando.

– Right to object to processing: you may withdraw your consent to your data being processed by objecting to further processing.

– Right to portability: under certain circumstances, you can request a copy of the personal data in a structured, commonly used, machine-readable format for transmission to another data controller.

– Right to not be subject to decisions based solely on automated processing: you may request that decisions not be taken on the basis of automated processing alone, including profiling, which produces legal effects and may significantly affect the data subject.

In some cases, your request may be denied if you ask for the erasure of data necessary for the fulfilment of legal obligations. If you have any complaints about the processing of your data, you can file a complaint with the data protection authority.

 

Who is responsible for the accuracy and veracity of the data provided?

The user is solely responsible for the veracity and correctness of the data supplied, exonerating Summa from any responsibility in this respect. The user guarantees and is wholly responsible for the accuracy, validity and authenticity of the personal data provided, and undertakes to keep such data duly updated. The user agrees to provide complete and correct information on the registration or subscription form. Summa reserves the right to terminate service agreements entered into with the user in the event that the details provided are false, incomplete, inaccurate or out of date.

Summa is not responsible for the veracity of information created by and duly attributed to a third-party source, nor therefore neither does it assume any liability for any hypothetical damages which may arise from the use of such information.

Summa reserves the right to update, modify or eliminate the information contained on its web pages, and may even limit or prohibit access to this information. Summa is exonerated from liability for any damage or harm suffered by the user as a result of errors, defects or omissions in information provided by Summa when this originates from third-party sources.

The user certifies to being over 14 years of age and to having the necessary legal capacity to consent to the processing of their personal data.

 

How do we process the personal data of minors?

Summa has adopted the legally required levels of security for the protection of personal data, and endeavours to install all the additional technical means and measures available to prevent the loss, misuse, alteration, unauthorised access or theft of the personal data supplied to Summa.

Summa is not responsible for any hypothetical damage or harm that may derive from interference, omissions, interruptions, computer viruses, telephone breakdowns or disconnections in the operation of this electronic system, as a result of causes beyond Summa’s control; for delays or blockages in the use of this electronic system caused by deficiencies or overloading of telephone lines or overloading of the data processing centre, the Internet or other electronic systems; or damage caused by third parties as a result of unlawful intrusions beyond Summa’s control. Notwithstanding, the user must be aware that internet security measures are not impregnable.

 

Links to other websites

The website www.summa.es may contain links to other websites. When you click on one of these links and access an external website, your visit will be subject to the privacy policy of that website, for which Summa is not in any way liable.

 

Can the Privacy Policy be modified?

This Privacy Policy is subject to change. We recommend you periodically review the Privacy Policy.

 

Legal Notice

In compliance with the provisions of Article 10 of Law 34/2002, of 11 July 2002, on information society services and e-commerce, we inform our users that the owner of the website located in the domain www.summa.es is:

Summa Comunicació, S.A.

A58933581

Calle Badajoz 127, naves 3-4, en la ciudad de Barcelona (Spain)

+34 932 081 090

barcelona@summa.es

Barcelona Companies Register T 10813, L 9765, S 2, F 210, H 125239, I 1, 21/07/1

 

User consent

This Legal Notice regulates access to and use of the website that Summa makes available to users of the Internet. Any person who accesses, browses, uses or participates in the services and activities offered on the website is considered a user.

The user is informed, and accepts, that access to this website in no way implies the commencement of a commercial relationship with Summa.

By accessing and browsing the website, the user implies their acceptance of these Conditions of Use in their entirety. If you do not agree to the terms and conditions, you should refrain from using the website.

 

Access to the website

The website may be freely accessed at no cost to the user. Certain services may be subject to the user entering into a services agreement.

If the user is required to provide personal data to access any of these services, the collection and processing of the data will be carried out in accordance with the regulations currently in force, specifically, the GDPR. To find out more, see our Privacy policy.

 

Content and use

While visiting the website, users must behave responsibly and in accordance with current legislation, good faith and this Legal Notice, and respecting the intellectual and industrial property rights owned by Summa or any other physical or legal persons.

The use of any of the content of the website for potentially or actually illicit purposes is totally prohibited, as well as the carrying out of any action not consented to by Summa that causes or could cause damage or alterations of any kind to the website or its content.

The owner of the website does not identify with the opinions expressed on it by its collaborators. The company reserves the right to make such unannounced changes to the website as it deems appropriate, and may change, delete or add to the content and services provided, as well as the way in which these are presented or located on its servers.

 

Intellectual and industrial property rights

The intellectual property rights of the website’s content, graphic design and codes are owned by Summa. The reproduction, distribution, public communication, transformation or any other activity involving the content of the website is therefore prohibited, irrespective of whether the sources are acknowledged, unless with the express written consent of Summa. All commercial names, brands or distinctive symbols of any kind found on the company’s website are the property of their owners and are protected by law.

Summa grants no licences or authorisations of any kind to use its intellectual and industrial property rights or any other property or right related to the website, and in no case will it be understood that the user’s accessing and browsing of the website implies waiver, transmission, licence or total or partial assignment of these rights by Summa.

Any use of this content not previously authorised by Summa will be considered a serious breach of intellectual or industrial property rights and will give rise to the corresponding legal liabilities. Summa reserves the right to bring the corresponding judicial and extrajudicial actions against the user.

 

Liability and guarantees

Summa declares that, within the limits of its capabilities and the state of technology, it has adopted the necessary measures to enable its website to function correctly, as well as ensure the absence of viruses and other harmful components. However, Summa may not be held responsible for situations including, but not limited to, the following:

– Continuity and availability of the content.

– Absence of errors in said content and correction of any defects.

– Absence of viruses and/or other harmful components.

– Damage or harm caused by any person violating Summa’s security systems.

– Use made of its website content by users of the website. Consequently, Summa does not guarantee that the use made by users of its website content, if any, complies with this Legal Notice, nor that use of the website is conducted in a diligent manner.

– Use of the website by minors or the sending of their personal data without their guardians’ permission, the guardians being the parties responsible for minors’ use of the Internet.

– Content accessed by the user via unauthorised links or introduced by users through comments or similar tools.

– The introduction of erroneous data by the user or a third party.

Summa may temporarily suspend access to the website for maintenance, repair, update or improvement operations without prior notice. Notwithstanding, wherever circumstances allow, Summa will inform the user, sufficiently in advance, of the scheduled date for suspension of the website service.

Likewise, in accordance with articles 11 and 16 of Law 34/2002, of 11 July, on information society services and e-commerce (LSSICE), Summa undertakes to eliminate or, where appropriate, block any content that may affect or contravene current legislation, the rights of third parties, or public morality and order.

 

Cookies

Summa uses cookies to personalise and optimise your browsing experience on the website. Cookies are physical pieces of information stored on the user’s own computer. The purpose of the information collected by the cookies is to facilitate the user’s navigation of the portal and optimise their browsing experience. The data collected by the cookies may be shared with the cookies’ creators, but under no circumstances will the information obtained by them be associated with personal data or data that could identify the user.

Notwithstanding, should you object to the installation of cookies on your hard drive, you have the option to change your browser settings to block the installation of these files. For more information, please consult our Cookies policy

 

Links

The presence on the website of links to other internet sites is for information purposes only and under no circumstances implies any suggestion, invitation or recommendation on the part of Summa.

Summa will assume no liability for content accessed via a link to a third-party website, nor will it guarantee the reliability, accuracy, range, veracity, validity or technical availability of said content.

In the event that other websites establish links to the Summa website, it will not be understood that Summa has authorised either the link or the website content to which the link directs, nor may the website which includes the link contain inappropriate, defamatory, illegal, obscene, illicit or other content in contravention of current legislation.

Summa reserves the right to contact the owner of the website containing the link if it considers it to be in contravention of the regulations, and to take the corresponding extrajudicial legal actions.

 

Modification of terms and conditions

Summa expressly reserves the right, without prior notice, to unilaterally modify this Legal Notice, in whole or in part. You, the user, acknowledge and accept that it is your responsibility to periodically review this Legal Notice.

 

Applicable law and jurisdiction

As a general rule, relations between Summa and the users of the telematic services present on its website will be subject to Spanish legislation and jurisdiction.