BASIC Information on Data Protection

Responsible: SUNWAY SL
Purpose: Provision of online services, Web user management, commercial communications related to our services.
Legitimation: Express consent and legitimate interest.
Recipients No data will be transferred to third parties, unless legally obliged to do so.
Rights: Access, rectify and delete data, as well as other rights, as explained in the additional information.
Additional information: You can address your communications and exercise your rights by sending a request to the following e-mail address:

Additional information on data protection

In SUNWAY SL we work to offer you through our products and services the best possible experience.
In some cases, it is necessary to collect information to achieve this. We care about your privacy and we believe that we should be transparent about it.
Therefore, and for the purposes of 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 personal data and on the free movement of such data, and the Law 34/2002, of July 11, 2002, of Services of the Information Society and Electronic Commerce (hereinafter, “LSSI”), SUNWAY SL informs the user that, as the data controller, will incorporate the personal data provided by users in an automated file.
Our commitment begins by explaining the following:
– We collect your data to improve the user experience, serving your interests and needs.
– We are transparent about what information we collect about you and why we collect it.
– Our intention is to provide you with the best possible experience. Therefore, when we use your personal information, we will always do so in a compliant manner, and where necessary, we will ask for your consent.
– We understand that your information belongs to you. Therefore, if you choose not to give us permission to process it, you can ask us to stop processing it.
– Our priority is to ensure your security and to process your data in accordance with EU law.
For more information on how we process your data, please see the different sections of the privacy policy below:

Who is responsible for the processing of your data?

This document constitutes the DATA PROTECTION Policy that applies to all personal data that SUNWAY SL treats about you. Below we inform you about the identification data of the CONTROLLER of the treatment:

Data Controller: SUNWAY SL
CIF: B-08370827
Postal Address: CTRA.DE VILANOVA, 64 – 08870 — SITGES
Contact Telephone: 938.110.471

SUNWAY SL has designated a Data Protection Officer or an internal contact person within its organisation. If you wish to make a query in relation to the processing of your personal data, you can contact him by email

What personal data do we collect?

The personal data that the user may provide:
– Name, address and date of birth.
– Telephone number and e-mail address.
– Location.
– Payment and refund information.
– IP address, date and time you access our services, internet browser you use and details of your device’s operating system.
– Any other information or data you choose to share with us.

In some cases, it is mandatory to fill in the registration form to access and enjoy certain services offered on the Web; likewise, failure to provide the personal data requested or not accepting this data protection policy means the impossibility of subscribing, registering or participating in any of the promotions in which personal data is requested.

Why and for what purpose we treat your data?

In SUNWAY SL we process the information provided by interested parties for the following purposes:
– Manage orders or hire any of our services, either online or in physical shops.
– Manage the delivery of the information requested.
– To develop commercial actions and carry out the maintenance and management of the relationship with the user, as well as the management of the services offered through the website and the information tasks, being able to carry out automatic assessments, obtain profiles and segmentation tasks of the customers in order to personalise the treatment according to their characteristics and needs and improve the customer’s online experience.
– Develop and manage contests, sweepstakes or other promotional activities that may be organised.
– In some cases it will be necessary to provide information to the Authorities or third party companies for auditing purposes, as well as to handle personal data from invoices, contracts and documents in order to respond to claims from customers or Public Administrations.

We inform you that the personal data obtained as a result of your registration as a user will form part of the Register of Processing Activities and Operations (RAT), which will be updated periodically in accordance with the provisions of the RGPD.

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

The processing of your data may be based on the following legal bases:
– Consent of the data subject for the contracting of services and products, for contact forms, requests for information or registration in e-newsletters.
– Legitimate interest for the processing of our customers’ data in direct marketing actions and express consent of the data subject for all matters relating to automatic assessments and profiling.
– Fulfilment of legal obligations for fraud prevention, communication with public authorities and third party claims.

How long do we keep your data?

The processing of data for the purposes described above will be kept for the time necessary to fulfil the purpose for which it was collected (for example, for the duration of the business relationship), as well as for compliance with the legal obligations arising from the processing of the data.

To which recipients is your data disclosed?

In some cases, only when necessary, SUNWAY SL will provide user data to third parties. However, data will never be sold to third parties. External service providers (e.g. payment providers or delivery companies) with whom SUNWAY SL works may use the data to provide the corresponding services, however, they will not use such information for their own purposes or for transfer to third parties.
SUNWAY SL endeavours to ensure the security of personal data when it is sent outside the company and ensures that third party service providers respect confidentiality and have appropriate measures in place to protect personal data. These third parties are obliged to ensure that the information is handled in accordance with data privacy regulations.
In some cases, personal data may be required by law to be disclosed to public bodies or other parties, only what is strictly necessary for the fulfilment of such legal obligations will be disclosed.
Personal data obtained may also be shared with other group companies.

Where is your data stored?

In general, data is stored within the EU. If data is sent to third parties outside the EU, we will ensure that they offer a sufficient level of protection, either because they have Binding Corporate Rules (BCR) or because they have signed up to the Privacy Shield.

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

You can send your communications and exercise your rights by sending a request to the following e-mail address:
Pursuant to the provisions of the GDPR, you can request:

– Right of access: you can request information about the personal data we hold about you.
– Right of rectification: you can communicate any change in your personal data.
– Right to erasure and the right to be forgotten: you can request the deletion of your personal data after it has been blocked.
– Right to limit processing: this means restricting the processing of personal data.
– Right to object: you can withdraw your consent to the processing of your data, opposing further processing.
– Right to portability: in some cases, you may request a copy of the personal data in a structured, commonly used and machine-readable format for transmission to another controller.
– Right not to be subject to individualised decisions: you can ask not to be subject to decisions based solely on automated processing, including profiling, that produce legal effects or significantly affect the data subject.
– In some cases, your request may be refused if you request the deletion of data necessary for compliance with legal obligations.

You can also lodge a complaint with the data protection authority if you have a complaint about the processing of your data.

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

The user is solely responsible for the accuracy and correctness of the data provided, exonerating SUNWAY SL from any liability in this regard. Users guarantee and respond, in any case, the accuracy, validity and authenticity of the personal data provided, and undertake to keep them updated. The user agrees to provide complete and correct information in the registration or subscription form. SUNWAY SL reserves the right to terminate the contracted services that have been concluded with users, if the data provided is false, incomplete, inaccurate or outdated.

SUNWAY SL is not responsible for the accuracy of the information that is not produced by itself and of which another source is indicated, so neither assumes any responsibility for any hypothetical damages that may arise from the use of such information.

SUNWAY SL reserves the right to update, modify or delete information contained in its Web pages may limit or deny access to such information. SUNWAY SL is exonerated from liability for any loss or damage you may suffer as a result of errors, defects or omissions in the information provided by SUNWAY SL provided it comes from outside sources.
Also, the user certifies that he/she is over 14 years old and has the necessary legal capacity to provide consent for the processing of personal data.

How do we process the personal data of minors?

In principle, our services are not specifically addressed to minors. However, in the event that any of them are addressed to minors under fourteen years of age, in accordance with article 8 of the RGPD and article 7 of the LO3/2018, of 5 December (LOPDGDD), SUNWAY SL will require the valid, free, unequivocal, specific and informed consent of their legal guardians to process the personal data of minors. In this case, it will require the
ID card or other form of identification of the person giving consent will be required.
In the case of persons over fourteen years of age, the data may be processed with the consent of the user, except in those cases in which the law requires the assistance of the holders of parental authority or guardianship.

What security measures do we apply to protect your personal data?

SUNWAY SL has adopted the security levels of protection of personal data legally required, and tries to install those other means and additional technical measures at its disposal to prevent the loss, misuse, alteration, unauthorized access and theft of personal data provided to SUNWAY SL.
SUNWAY SL is not responsible for hypothetical damages that may result from interference, omissions, interruptions, computer viruses, telephone faults or disconnections in the operation of this electronic system, caused by reasons beyond SUNWAY SL; delays or blockages in the use of this electronic system caused by deficiencies or overloads of telephone lines or overloads in the Data Processing Center, the Internet system or other electronic systems, as well as damage that may be caused by third parties through illegal interference beyond the control of SUNWAY SL. However, the user must be aware that Internet security measures are not impregnable.

Links to other websites

The SUNWAY SL website may contain links to other websites. By clicking on one of these links and accessing an external Web site, the visit will be subject to the privacy policy of that Web site, being SUNWAY SL disassociated from any kind of responsibility about their privacy policy.

How do we use cookies?

The website and the RRSS of SUNWAY SL use cookies, in order to optimize and personalize your navigation through it. Cookies are physical information files that are hosted on the user’s own terminal, the information collected through cookies is used to facilitate user navigation through the portal and optimize the browsing experience. The data collected through cookies may be shared with the creators of the same, but in no case will the information obtained by the same be associated with personal data or data that can identify the user.
However, if you do not want cookies to be installed on your hard drive, you can configure your browser to prevent the installation of these files. For more information, please see our Cookie Policy.

Can the privacy policy be changed?

This privacy policy is subject to change. We recommend that you review the privacy policy from time to time.