At TRANSMIL we work with the aim to offer the user the best possible experience through our products and services. In some cases, it is necessary to gather information in order to do so. We care about your privacy and believe that we must be transparent.

Therefore according to what is established in EU REGULATION 2016/679 of the EUROPEAN PARLIAMENT AND COUNCIL dated 27th of April 2016 (from hereon RGPD) related to the protection of physical persons with regard to the treatment of personal data and the free circulation of this, an ACT 34/2002 of Electronic Commerce and Services of Information Society (from hereon LSSI), TRANSMIL, as the entity responsible for such data treatment, informs the user personal data provided by the user will be incorporated.

Personal data of each user is gathered and treated by means of registry forms or emails, and its treatment is regulated by the present Privacy Policy. This data is necessary for the management and maintenance of some of the services rendered and is included in the specific user files of the services provided by TRANSMIL.

The user is obliged to provide true, exact and complete information regarding their identity. The user shall in any case be accountable for the veracity of the data provided, and TRANSMIL reserves the right to exclude from the services provided any user who has provided false information, without prejudice of any other legal actions that may be taken. Furthermore, the user must certify that they are at least 14 years old and that they have the necessary legal capacity to consent to the treatment of their personal data.

The compromise of Transmil begins with the following explanation:

• The user’s data is gathered so that their experience as users improves in relation to their interests and necessities.
• Transmil shows transparency in relation to the data obtained about the user and the reasons why this data is gathered.
• The intention of Transmil is to offer the best possible experience. That is why, before the user’s personal data is used and when necessary, consent will be requested and these will be used in compliance with the existing regulations.
• Transmil understands that this data belongs to the user. Therefore, should the user decide not to grant authorisation or processing of the data, the user may choose to do so.
• The priority of Transmil is to guarantee the security of the user and to treat their data in accordance with the European regulations.

If the users wish to obtain more information on the treatment of their data, the following sections of the privacy policy may be consulted:

Who is responsible for the treatment of the user’s personal data?

TRANSMIL, S.A. with VAT No. ESA20078523 and fiscal address in PORTUETXE 63, 3 20018 Donostia-San Sebastian, Spain, telephone number (+34) 943 224 170 and email address info@transmil.es, is responsible for the treatment of the personal data provided by the user when accessing and using the website.

TRANSMIL compromises to apply the IT security measures provided by the Regulation with the aim to avoid the access or wrongful use, manipulations, damage or loss of the data.

Which personal data is gathered?

The personal data the user might provide are as follows:

• Name and address.
• Telephone number and email address.
• IP address, date and time the user has accessed the services, browser used, and the operating system of the equipment.
• Any other information or data the user chooses to share.

Is some cases, filling out the registry form is obligatory in order to access and enjoy the services offered in the web; furthermore, not providing the requested personal data or not accepting the present data protection policy means that it will not be possible to subscribe, register or participate in any of the promotions where personal data is requested.

Why, and what is the user’s data treated for?

The operations, technical management and procedures, whether they are carried out automatically or not, that allow the gathering, storage, modification, transfer and any other actions related to personal data are to be considered as personal data treatment.

TRANSMIL treats the information provided by the users with the following purposes:

Manage and send the information requested and reply to the consultation or requests made by the user through the website, as well as providing the services offered to those who may be interested.

Develop commercial actions and carry out maintenance and management of the relationship with the user, as well as managing the services and information offered through the website.

The fields in the registration from must be filled out obligatorily so that TRANSMIL can fulfil all the purposes mentioned earlier.

In some cases it will be necessary to provide information to the authorities or third parties for auditing purposes as well as managing data on invoices, contracts or Documentation in order to respond to claims made by clients or public administrations.

What is the legitimization for the treatment of the user’s data?

The treatment of the personal data provided by the user is carried out based on the legal bases that legitimise such use:

Free, specific, informed and unequivocal consent, as with the Reading of the present Privacy Policy, the user is informed and, in case they agree, the user can accept the same by mean s of a declaration or a clear affirmative action like the one present in the field available for such purpose.

Legitimate interest for the treatment of the client data in direct marketing actions and express consent of the interested party.

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

Should the interested party not provide the said data or this be incorrect or inexact, TRANSMIL will not be able to attend to the request and it will be impossible to provide the request information or carry out the services. Therefore, TRANSMIL as the party responsible for the treatment of the data shall be exonerated of all accountability that may stem from the non-execution of the contracted service or of the consequences that may derive from such incorrect or inexact information.

How long is this data kept?

TRANSMIL as the party responsible for the treatment of the data, compromises to store and manage the personal data and information gathered through this webpage with due confidentiality whilst maintaining the existing professional relationship and the interested person does not request the elimination of the data, and in any case no longer that 5 years from the end of the relationship established between the user and TRANSMIL. Nonetheless, the party responsible for the treatment may keep, duly protected, the data in order to attend to possible administrative or legal accountability.

Who are the recipients of the user’s data?

Generally, TRANSMIL will not communicate personal data to third parties except when, and only prior authorisation from the user, the provision of a Service implies the necessity of a contractual relationship with another party also responsible for data treatment and when this is strictly necessary for the management and maintenance of the relationship between the user and mentioned party. This will only last the necessary time in order to enable the execution of the contracted service and under the same conditions and accountability demanded of the party responsible for the treatment.

Once the service has been completed, the party treating the data will return the same to the party responsible for the treatment and will delete any copy they may have.

Furthermore, in some cases, the law may demand that personal data is revealed to public entities or other parties; in these cases, only strictly essential data will be revealed for the fulfilment of such legal obligations.

Where is the user’s data stored?

Generally, the user’s data is stored within the EU. Data that is sent to third parties outside the EU will have a sufficient level of protection either because there are Binding Corporate Regulations (BCR) or they have been adhered to ‘Privacy Shield’.

User’s rights and how to exercise them.

• Any person has the right to obtain information on whether TRANSMIL is treating data related to them or not.
• The persons interested have the right to access their personal data as well as to request the rectification of inexact data or, if necessary, delete this when amongst other reasons the data is no longer necessary for the purposes it was gathered for.
• In certain circumstances, the persons interested may request the limitation of the treatment of their data, in which case TRANSMIL will only keep this for the exercise or defence against claims.
• In certain circumstances and for reasons related to their specific situation, the persons interested may oppose to the treatment of their data. TRANSMIL will cease to treat this data, except when for legitimate and imperious reasons or the exercise or defence against possible claims.
• The user has the right to portability, that is to say, that the personal data they may have provided, is transmitted directly to another party in structured format, mechanical reading and common use when technically possible.
• The owner of the data or their legal representative (showing proof of identity) may exercise the said rights by means of sending an email to the electronic address info@transmil.es or by means of ordinary post to: PORTUETXE 63, 3 20018 Donostia-San Sebastián, España.
• They may obtain additional information as regards their right from the Spanish Agency of Data Protection (Agencia Española de Protección de Datos) at http://www.agpd.es, or the corresponding authority in the country they are in.
• When the holder of the rights is not satisfied with the exercise of the same, they may claim the assistance of the Spanish Agency of Data Protection (or the corresponding authority) by means of a Rights Tutelage Claim (http://www.agpd.es).

How personal data of under aged persons is used.

In principle the services provided by TRANSMIL are not specifically directed to under aged persons. In the case of persons older than 14, treatment of the data may be carried out with the consent of the user, except when the law obliges the assistance of the holder of custody or tutelage.

Security measures taken for the protection of the user’s personal data.

TRANSMIL has enforced the personal data security protection levels legally required and makes sure that other additional security and technical measures are applied in order to avoid the loss, incorrect use, alteration, non-authorised access or theft of the personal data provided by the user.

Furthermore, TRANSMIL has adopted all the organisational and technical measures in order to guarantee the security and integrity of the personal data being treated as well as to avoid its loss, alteration and/or access by non-authorised third parties.

Links to other websites.

The present website may have links to other webpages. When clicking on one of these and accessing an external website, the visit will be subject to the privacy policy of the said website and TRANSMILL shall not be accountable in any case with regard to the privacy policy of the said website.

How we use Cookies.

The TRANSMIL website and social media uses cookies in order to optimise and personalise the user’s experience. Cookies are physical information files housed in the user’s own terminal; the information gathered by means of the cookies facilitates the use of website and optimises the experience of the user. The data gathered by means of the cookies may be shared with the creators of the same but under no circumstances will the information obtained be associated with the personal data that may identify the user.

Nevertheless, if the user does not wish to have cookies installed in their hard-drive, they have the option to configure the browser so that it blocks the installation of these files. To obtain more information consult or Cookies Policies.

Can the privacy policy be modified?

This privacy policy may be modified. We recommend the user to check it on a regular basis.

Version: February 2020.