Privacy Policy

The Privacy Policy forms part of the General Terms and Conditions governing this website.

Last version 7 May 2021.

Who is responsible for the processing of your data?

The data controllers are those described below, who, together, will be referred to as STARWOOD throughout the Privacy Policy:

LARMA SPV 2019 S.L.	B88389036	C/ Goya 6, 2º Planta, 28001 Madrid
RACOL SPV 2019, S.L.	B88347166	C/ Goya 6, 2º Planta, 28001 Madrid
NICAM SPV 2019, S.L.	B88347158	C/ Goya 6, 2º Planta, 28001 Madrid
TUSAM SPV 2019, S.L.	B88347133	C/ Goya 6, 2º Planta, 28001 Madrid
NEVAL SPV 2019, S.L.	B88347141	C/ Goya 6, 2º Planta, 28001 Madrid
PALLARS 193-205 S.L.	B86578044	C/ Goya 6, 2º Planta, 28001 Madrid
SURFING MOON INVESTMENTS, S.L	B86534088	C/ Goya 6, 2º Planta, 28001 Madrid
DONTE SPV 2018 S.L.U.	B88055892	C/ Goya 6, 2º Planta, 28001 Madrid
BOSEAL SPV 2018 S.L.U.	B88055850	C/ Goya 6, 2º Planta, 28001 Madrid

You may contact us in any way by writing to us at the following address or email address: We reserve the right to modify or adapt this Privacy Policy at any time. We recommend you to review it, and if you have registered and access your account or profile, you will be informed of the modifications. If you are one of the following groups, please consult the drop-down information:

WEB OR EMAIL CONTACTS

What data do we collect through the website?

We may process your IP address, what operating system or browser you use, and even the length of your visit, anonymously. If you provide us with data in the contact form, you will be identified so that we can contact you, if necessary.

For what purposes will we process your personal data?

To answer your queries, requests or petitions.
To manage the requested service, answer your request, or process your request.
Information by electronic means, related to your request.
Commercial or event information by electronic means, provided that express authorisation has been given.
To carry out analyses and improvements on the Web, on our products and services. To improve our commercial strategy.

What is the legitimacy for the processing of your data?

The acceptance and consent of the interested party, granted through a voluntary action, as in cases where to make a request it is necessary to fill in a form and click on the send button, the completion of the same will necessarily imply that he/she has been informed and has expressly given his/her consent to the content of the clause attached to the form or acceptance of the privacy policy. All our forms have the symbol * in the obligatory data. If you do not provide these fields, or do not tick the checkbox for acceptance of the privacy policy, the information will not be allowed to be sent. It usually has the following formula: “□ I am over 14 and I have read and accept the Privacy Policy.”

For how long will we keep personal data?

Until the revocation of the consent given.

NEWSLETTER CONTACTS

What data do we collect through the Newsletter?

On the website, you can subscribe to the newsletter if you provide us with an e-mail address, to which the newsletter will be sent. We will only store your email address in our database and will send you periodic emails until you unsubscribe or we stop sending emails.

You will always have the option to unsubscribe, in any communication.

For what purposes will we process your personal data?

To manage the requested service.
Information by electronic means, related to your request.
Commercial or event information by electronic means, as long as there is express authorisation.
To carry out analyses and improvements in the sending of mailings, in order to improve our commercial strategy.

What is the legitimacy for the processing of your data?

The acceptance and consent of the interested party. In those cases where you subscribe, it will be necessary to accept a checkbox and click on the send button. This necessarily implies that you have been informed and have expressly given your consent to receive the Newsletter. If you do not check the checkbox to accept the privacy policy, the information will not be sent. It normally has the following formula: “□ I am over 14 and I have read and accept the Privacy Policy.”

For how long will we keep personal data?

Until the revocation of the consent given.

CUSTOMERS

For what purposes will we process your personal data?

Drawing up the budget and monitoring it by means of communications between both parties.
Information by electronic means, concerning your request.
Commercial or event information by electronic means, as long as there is express authorisation.
To manage the administrative, communications and logistics services carried out by the Responsible Party.
Invoicing and declaration of the appropriate taxes.
Carrying out the corresponding transactions.
Control and collection procedures.

What is the legitimacy for the processing of your data?

The existence of a contractual relationship between the parties. The processing is necessary for the performance of a contract to which the data subject is a party or for the implementation of pre-contractual measures at the request of the data subject.

For how long will we keep personal data?

For the duration of the relationship between the parties and for the statute of limitations arising therefrom.

SUPPLIERS

For what purposes are we going to process your personal data?

Information by electronic means, which relates to your request.
Commercial or event information by electronic means, provided there is express authorization.
Manage the administrative, communications and logistics services performed by the Controller.
Billing.
Carry out the corresponding transactions.
Invoicing and declaration of appropriate taxes.
Control and recovery procedures.

What is the legitimacy for the processing of your data?

The legal basis is the acceptance of a contractual relationship, or failing that, your consent when contacting us or offering us your products in any way.

How long will we keep personal data?

During the validity of the relations between the parties and for the limitation periods derived from them.

And data on minors?

We do not process data of children under 14 years of age. Therefore, please refrain from providing them if you are not of that age or, where appropriate, from providing data from third parties who do not have the aforementioned age. STARWOOD is exempt from any liability for failure to comply with this provision.

Will we communicate by electronic means?

They will only be carried out to manage your request, if it is one of the means of contact that you have provided us.

If we make commercial communications, they will have been previously and expressly authorized by you.

What security measures do we apply?

You can rest assured: We have adopted an optimal level of protection for the Personal Data we handle, and we have installed all the means and technical measures at our disposal according to the state of technology to prevent loss, misuse, alteration, unauthorized access and theft of Personal Data.

To which recipients will your data be communicated?

Your data will not be transferred to third parties, except under legal obligation. Specifically, they will be communicated to the State Tax Administration Agency and to banks and financial entities for collection of the service provided or product acquired, as well as to those responsible for the processing necessary for the execution of the agreement.

In the case of purchase or payment, if you choose an application, website, platform, bank card, or some other online service, your data will be transferred to that platform or processed in its environment, always with maximum security.

When we order it, the web development and maintenance, web hosting/hosting company will have access to our website. They will have signed a service provision contract that requires them to maintain the same level of privacy as us. Any international data transfer when using American applications will adhere to the Privacy Shield agreement, which guarantees that American software companies comply with European data protection policies regarding privacy.

What Rights do you have?

To know if we are processing your data or not.
To access your personal data.
To request rectification of your data if it is inaccurate.
To request the deletion of your data if it is no longer necessary for the purposes for which it was collected or if you withdraw the consent granted.
To request the limitation of the processing of your data, in some cases, in which case we will only keep them in accordance with current regulations.
To carry your data, which will be provided to you in a structured, commonly used or machine-readable format. If you prefer, we can send them to the new person in charge that you designate for us. It is only valid in certain cases.
To file a claim with the Spanish Data Protection Agency or competent control authority, if you believe that we have not served you correctly.
To revoke consent for any treatment to which you have consented, at any time.

If you modify any information, please let us know so we can keep it updated.

Do you want a form to exercise Rights?

We have forms for the exercise of your rights, ask us by email or if you prefer, you can use those prepared by the Spanish Data Protection Agency or third parties.

These forms must be signed electronically or be accompanied by a photocopy of your DNI.

If someone represents you, you must attach a copy of their ID, or have them sign it with their electronic signature.

The forms can be submitted in person, sent by letter or by email to the address of the Controller at the beginning of this text.

How long does it take us to respond to the Exercise of Rights?

It depends on the law, but a maximum of one month from your request, and two months if the issue is very complex and we notify you that we need more time.

Do we process cookies?

If we use other types of cookies that are not necessary, you can consult the cookie policy in the corresponding link from the beginning of our website.

How long will we keep your personal data?

Personal data will be maintained as long as you remain linked to us.

Once you unlink, the personal data processed for each purpose will be kept for the legally established periods, including the period in which a judge or court may require them in accordance with the statute of limitations for judicial actions.

The processed data will be maintained as long as the legal periods mentioned above do not expire, if there is a legal obligation to maintain it, or if this legal period does not exist, until the interested party requests its deletion or revokes the consent granted.

We will maintain all information and communications related to your purchase or the provision of our service, for as long as the guarantees of the products or services last, to address possible claims.