In accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (“GDPR”) and the Organic Law 3/2018 of 5 December on the Protection of Personal Data and guarantee of digital rights, Smart Way VP, S.L. (Smart Way) informs all users of its website, about the processing of their personal data, those provided during access and use of the site.

Who is responsible for the processing of your data?

Site owner: Smart Way VP, S.L.

CIF: B16888224.

Registered Office: C/ Ramon Albo, 54, 3-4, 08027, Barcelona.

Email: GDPR@smartway.es

For what purposes will we process your personal data?

• Respond to inquiries and / or requests for information transmitted by users through the contact email provided on the website.
• To provide you with the services that, if applicable, you have contracted through the website.
• Enable the sending of our newsletter or other communications about our activities and services.

What is the legitimacy for the processing of your data?

• Respond to inquiries and/or requests for information sent by users through the contact form provided on the website. The consent expressed with you, at the time of your request (Art. 6.1.a. RGPD).
• To provide you with the services that, if any, you may have contracted. To enable the execution of the contracted services (Art. 6.1.b. RGPD).
• For the sending of communications by Smart Way, e.g. newsletter, etc. Your consent (Art. 6.1.a. RGPD) or if you are already a customer or have been, art 21.2 LSSICE.

To which recipients will your data be communicated?

The communication of the data provided through this website is not foreseen, nor during the provision of services unless, in some specific case, it is essential to comply with the stated purposes.

How long will we keep your data?

In general, the data provided will be retained:

• For as long as we believe that the data collected is necessary to respond to your specific requests.
• During the legal terms established by tax regulations (4 years).
• Until you do not manifest it, for example, through the mechanism enabled in all communications. Or until we no longer believe it is necessary to send such communications.

In any case, they will be deleted when you request it and their deletion is possible.

Where do we obtain your data?

The data that we are going to treat, are those that you may provide us, throughout our relationship.

What are your rights when you provide us with your data?

Insofar as Smart Way processes your personal data, you have the right to request:

Access – The interested party shall have the right to obtain, from Smart Way, confirmation as to whether or not data concerning him/her are being processed, as well as detailed information about certain aspects of the processing being carried out.

Rectification: The interested party shall have the right to obtain the rectification of inaccurate personal data concerning him/her or the completion of incomplete data.

Suppression: The interested party will have the right to request the suppression of his/her personal data, in any case the suppression will be subject to the limits established in the regulatory norm.

Limitation of processing – The data subject shall have the right to request the limitation of the processing of his/her personal data.

In certain circumstances and for reasons related to their particular situation, data subjects may object to the processing of their data. Smart Way will stop processing the data, except for legitimate, compelling reasons, or the exercise or defense of possible claims.

Right to data portability – In other words, you have the right to receive the personal data concerning you that you have provided to a data controller in a structured, commonly used and machine-readable format and to transmit it to another data controller.

The aforementioned rights may be exercised by sending a request to Smart Way C/ Ramon Albo, 54, 3-4, 08027 Barcelona, or by sending an e-mail to GDPR@smartway.es.

What happens if I do not provide the requested data?

The refusal to provide the data indicated as mandatory, could result in the impossibility to access the service or respond to your requests.

International transfers.

Smart Way has contracted the services of the electronic payment platform Stripe, domiciled in the USA, for the management of website payments. In order to make the payment, the user must provide Stripe with his/her data and accept their own privacy policies. In any case, Stripe declares to have subscribed to the Standard Contractual Clauses (SCC) and to comply with the requirements established in the Privacy Shield agreement. More information at https://stripe.com/es/privacy or through privacy-acs@stripe.com.

Guardianship of the control authorities.

If you believe it appropriate, you may request the protection of the Spanish Data Protection Agency by filing the corresponding complaint. www.agpd.es. C/ Jorge Juan nº 6 28001 Madrid.