Privacy policy

The Privacy Policy forms part of the Legal Notice that governs the Web Page: together with the Cookies Use Regulations.

The website is owned by Sugimat, S.L. and complies with the requirements derived from Law 34/2002, of 11 July, on Information Society Services and Electronic Commerce, and current legislation on the protection of personal data and, in particular, Regulation (EU) 2016/679 of the European Parliament and of the Council, of 27 April 2016, on the protection of individuals with regard to the processing of personal data and on the free movement of such data.

Sugimat, S.L. reserves the right to modify or adapt this Privacy Policy at any time. Therefore, we recommend that you review it every time you access the Website. In the event that you have registered on the website and access your account or profile, when you access it, you will be informed in the event that there have been substantial changes in relation to the processing of your personal data.



The data collected or provided voluntarily through the Website, either by browsing it, as well as all those that you may provide us with in the contact forms, via email or by telephone, will be collected and processed by the File Manager, whose details are indicated below:


Sugimat, S.L.



Postal address:

Quart de Poblet – 46930 – Quart de Poblet (Valencia/València)





Mercantile Register:

Inscrita en el Registro Mercantil de Valencia. Tomo 2765, Libro 82, Folio 208, Sección 8, Hoja V 1254, I/A 25


If, for any reason, you wish to contact us about any matter related to the processing of your personal data or privacy (with our Data Protection Officer), you can do so by any of the means indicated above.


When, why, by whom, how, for what purpose and for how long do we process your personal data?

When and why?

You can browse most of our websites without providing any personal information, but in some cases this information is necessary to provide you with the electronic services you request from us.

If we need to collect personal data to provide the service to you, we will process the information in accordance with the policy set out in this document and in the specific terms and conditions of the particular service in question (if any), which contain specific privacy statements about the use of the data and tell you why, for what purpose, how, for how long we process your personal data and what security measures we implement.


Who collects your data?

The collection and processing of the personal data that you may provide to us is carried out by our company or, where appropriate, its data processors. In relation to the latter case, these processors are third parties who are contractually required to ensure that their activity respects the law and implement appropriate security measures to protect such data.


What for?

The personal data that we request from you, or that you provide to us as a result of your browsing, is used by us to manage, provide and improve the services that you have requested from us.

For example, we will process your personal data in order to manage the queries you send us, to manage your participation in personnel selection processes, to send you electronic communications if you so request, and/or to compile statistics.

In this regard, we ask you for an e-mail address when you use our contact forms on the website. We only collect the sender’s personal data necessary to reply to you.

When you subscribe to our newsletters, we also ask you for an e-mail address in order to provide you with the service. In any case, you can unsubscribe from the service whenever you wish and we provide you with the means to do so.


How do we process your data?

We only collect personal information to the extent necessary to achieve a specific purpose. The information will not be used for a purpose incompatible with the one described.

We only disclose information to third parties if it is necessary for the fulfilment of the purpose of the service and only to persons who need to know. All this in order to be able to provide the service, treating your personal data with confidentiality and reserve, in accordance with the legislation in force.

In any case, our entity adopts security measures to protect the data against possible abuse or unauthorised access, alteration or loss.


How long do we keep your data?

We store data only for as long as is necessary to fulfil the purpose of its collection or further processing. The period of data retention will depend on the service and each service will indicate the duration of the processing of personal data.

A table with the specific retention periods is provided at the end of this document.


For what purposes will we process your personal data?


– Customers:

We process your personal data for the purpose of (i) managing your purchase or service provided; (ii) maintaining the contractual and pre-contractual relationship for invoicing, drawing up estimates and following up the same, as well as sending you information by electronic means relating to your request; (iii) sending you communications on commercial information by electronic means that may be of interest to you, provided that you have express authorisation; (iv) we may draw up a commercial profile based on the information you provide us with in order to offer you products and services in accordance with your interests. No automated decisions will be made on the basis of such a profile.


– Suppliers:

We process your personal data for the purpose of (i) invoicing and (ii) maintaining commercial contact, (iii) as well as sending you information by electronic means about our products or services.


– Web or e-mail contacts:

We process your personal data in order to (i) answer your queries and requests; (ii) manage the service requested or process your order; (iii) send you commercial information by electronic means that may be of interest to you, subject to your express authorisation; (iv) we may draw up a commercial profile based on the information you provide us with in order to be able to offer you products and services in accordance with your interests. No automated decisions will be made on the basis of such a profile.


– Social media contacts:

We process your personal data in order to (i) answer your queries and requests, (ii) manage the requested service, answer your request or process your order and (iii) interact with you and create a community of followers.


– Job seekers:

We process your personal data in order to (i) count on you in recruitment selection processes, (ii) summon you for job interviews and evaluate your candidacy, (iii) communicate your curriculum to companies of the group, collaborators or related companies with the sole purpose of involving you in their selection processes, provided that you have given us your consent.


– Participants in our competitions

We process your personal data in order to manage your participation in the competitions we organise as well as to publicise the winners of the competition and the prize-giving ceremony.

Winning participants may be photographed or videotaped and broadcast in any of the media, our website or other media. Consequently it is possible that the image of the participants may be captured, recorded and/or reproduced in an ancillary manner to the main activity.


– Website users:

By browsing our website we collect information about your browser, your device and your use of our website as well as any information you provide to us when using our website. In an anonymised or aggregated form, we may record the IP address (the device’s Internet access identification number, which allows devices, systems and servers to recognise and communicate with each other).

The purpose of the processing is (i) to obtain practical knowledge about how users use our website to enable us to improve it; (ii) to perform statistical analysis to help us improve our business strategy; (iii) to perform web performance analysis and (iv) for technical security and system diagnostics.

The data we collect is not related to a specific user and will be stored in our databases.

The aforementioned data, as well as any personal data you may provide to us, is stored by means of cookies which are collected in a pseudonymised format and are subject to the submission of objections to the processing of this personal data, as detailed in the Cookie Policy.

You can consult the Cookie Policy in the corresponding section.

Your browsing information may be stored by Google Analytics, for which we refer to Google’s Privacy Policy, as Google collects and processes this information.

Similarly, from our website you can provide the utility of Google Maps, which may have access to your location, if permitted, in order to provide you with greater specificity about the distance and / or roads to our headquarters. In this regard, we refer to the privacy policy used by Google Maps, in order to know the use and processing of such data

In order to offer information or services of interest based on the User’s location, we may access data relating to the geolocation of the User’s device in those cases in which the user’s configuration for this purpose so permits.

The Portal may offer functionalities for sharing content through third party applications, such as Facebook or Twitter. These applications may collect and process information related to the user’s browsing on the different websites. Any personal information collected through these applications may be used by third party users of the same. Your interactions are subject to the privacy policies of the companies providing the applications.

The Portal may host blogs, forums, and other social networking applications or services in order to facilitate the exchange of knowledge and content. Any personal information provided by the user may be shared with other users of that service, over which we have no control.


What is the legitimacy for the processing of your data?


– Customers:

The legal basis for the processing of your data is (i) the execution of a contract and maintenance of the contractual relationship and (ii) your consent that is requested for the remission of offers of products and services through electronic means, without in any case the withdrawal of this consent conditioning the execution of the contract.


– Suppliers:

The legal basis for processing your data is (i) the performance of a contract to which the data subject is a party or for the implementation of pre-contractual measures.


– Website or e-mail contacts:

The legal basis for processing your data is (i) the data subject’s consent.

In those 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 you have been informed and have expressly given your consent to the content of the clause attached to the form or acceptance of the privacy policy.

All our forms have a check box that must be ticked to access the services offered.

The purposes of the treatment will be the following:

  1. a) To manage queries or requests for information that you send us via the Website, email or telephone.
  2. b) Sending communications, special promotions, news or actions that are of interest to you or that you request from us, including by electronic means. As this is an ancillary purpose to the main one, you must tick the box provided for this purpose.

The personal data that you provide us by this means will not be communicated to third parties, being Sugimat, S.L. who gives, directly answer to this type of consultations.


– Social media contacts:

The legal basis for the processing of your data is the acceptance of the contractual relationship with the relevant social network provider manifested when signing up for their application and in accordance with their privacy policies, which is external to us.


– You work with us:

In the event that you provide us with your curriculum vitae, either by means of the Web Page, e-mail or physically at the address or any Sugimat, S.L. headquarters, Sugimat, S.L. will incorporate them in its database. The curriculum will be stored for a period of 1 year, after which, if we have not contacted you, it will be deleted.

The legal basis for the processing will be based on the express consent given by the interested party for the processing of the data contained in the curriculum by sending it and ticking the box provided for this purpose.

The purpose of the treatment is to incorporate you to present and future selection processes of Sugimat, S.L. or of any entity belonging to the business group.

In the event that the interested party finally joins Sugimat, S.L. or any of the entities belonging to the business group as an employee, his/her data will be incorporated into a database owned by the same, in order to internally manage the employee-employer labour relationship.


– Sending of Newsletter:

The Web Page allows the option of subscribing to the Newsletter of Sugimat, S.L. To do so, it is necessary that you provide us with an e-mail address to which the Newsletter will be sent.

Such information will be stored in a database of Sugimat, S.L. in which it will remain registered until the interested party requests the cancellation of the same or, in its case, Sugimat, S.L. ceases to send it.

The legal basis for the processing of this personal data is the express consent given by all those interested parties who subscribe to this service by ticking the box provided for this purpose.

The data from e-mails will only be processed and stored for the purpose of managing the sending of the Newsletter by users who request it.


– Participants in our competitions

The legal basis for the processing of your data is your consent to register for the competition and accept the privacy policy and the competition rules.

The personal data collected will not be passed on to third parties.


– Website users:

The legal basis for the processing of data is our (i) legitimate interest in knowing our users’ browsing patterns in order to adapt to their interests and improve our relationship with them; as well as (ii) their consent when browsing our website and accepting the terms of use of cookies.


To whom will your data be disclosed?

Your data will not be disclosed to third parties outside the service we provide, unless legally obliged to do so. Specifically, they will be communicated to the State Agency of Tax Administration and to banks and financial institutions for the collection of the service provided or product purchased.

Your data may also be communicated to our service providers when necessary for the execution of the contract. In these cases, the data processor has undertaken by contract to use the data only for the purpose justifying the processing and to maintain appropriate security measures.


What security measures do we apply?

Rest assured, we have taken appropriate technical and organisational measures to ensure the confidentiality, integrity and availability of our processing of your personal data, in particular to prevent the loss, misuse, alteration, unauthorised access and theft of personal data.


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

You can exercise your rights of access, rectification, erasure, portability, limitation or opposition to the processing of your data, including the right to withdraw your consent, as detailed below:

Right of access: You can ask us whether and how we are processing your data.

Right of rectification: You can ask us to update your personal data if it is incorrect, and delete it if you wish.

Right to limitation of processing: In this case, your personal data will only be retained by us for the purpose of exercising or defending claims.

Right to object: Following your request to object to the processing, we will stop processing the data in the manner you have indicated, unless for compelling legitimate reasons or for the exercise or defence of possible claims, the data must continue to be processed.

Right to data portability: In the event that you want your data to be processed by another company, we will facilitate the portability of your data to the new data controller.

Right to erasure: You can request that we delete your data if it is no longer necessary for processing, if you withdraw your consent, if the processing is unlawful or if there is a legal obligation to do so. We will analyse the situation and apply the law.

If you need more information about your rights under the law and how to exercise them, we recommend that you contact the Spanish Data Protection Agency, which is the supervisory authority for data protection.

You can contact the Data Protection Delegate prior to filing a complaint against the data controller with the AEPD.

In the event that we have not attended to your exercise of your rights, you can file a complaint with the Spanish Data Protection Agency. 

We have forms for the exercise of rights that can be requested at the e-mail address mentioned above; you can also use the forms prepared by the Spanish Data Protection Agency or those of third parties. These forms must be signed electronically or be accompanied by a photocopy of your ID card. If acting through a representative in the same way, they must be accompanied by a copy of their DNI or with an electronic signature.

The forms must be submitted in person or sent by post or e-mail to the addresses that appear in the “Responsible party” section.

The maximum time limit for a decision is one month from receipt of your request.


How long will we keep your data?

Personal data will be kept for as long as you maintain your relationship with us.

At the end of this period, the personal data processed for each of the purposes indicated will be kept for the legally stipulated periods. If this legal period does not exist, until the interested party requests their deletion or revokes the consent granted, or for the period that a judge or court may require them in accordance with the statute of limitations for legal actions.

For each processing or type of data, we provide you with a specific period, which you can consult in the following table:






10 years


5 years

Human Resources

Payrolls, TC1, TC2, etc.

10 years


Until the end of the selection process, and 1 more year with your consent.


Data of temporary workers.

4 years

Data of temporary workers.

Up to 5 years after termination of employment


Databases or web visitors.

For the duration of the processing



10 years


5 years

Access control and video surveillance

Visitor list

30 days


30 days blocking

3 years destruction


Books and accounting documents.

6 years


Management of the company’s administration, rights and obligations relating to the payment of taxes.

10 years

Health and Safety 

Medical records of workers

5 years


Insurance policies

6 years (general rules)

2 years (damages)


Registration of all deliveries of goods or provision of services, intra-community acquisitions, imports and exports for VAT purposes.

5 years


Processing of personal data 

3 years

Personal data of employees stored on networks, computers and communications equipment used by employees, access controls and internal management/administration systems

5 years

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