What is this policy about?
This is our Privacy and Data Protection Policy. It explains who we are, why we process personal data and how we do this, and if you are the person whose personal data we are processing, what rights you have and how you can contact us should it be necessary.
Who are we?
We are Distribuciones Suner S.L.U. At the bottom of this policy you will find our contact details and other information. We are responsible for processing the personal data processed in accordance with this policy (unless this policy specifies otherwise).
Whose personal data are we processing?
We can process personal data about you in the following cases:
- You are a customer or supplier of ours.
- You use our products or services.
- You work for one of our customers or suppliers or for someone that uses our products or services.
- You are someone (or you work for someone) to whom we would like to sell or publicise our goods or services. In this case, we may have obtained your data directly from you (for example, via our website or at a trade fair or show) or from another source.
What personal data do we process?
We can process personal data about you that we have obtained from you or from another source. The personal data about you that we process may include the information listed below.
Your personal data. We can process your personal data, such as:
- Your name.
- Who you work for and your role or department.
- Your address, telephone number, email address or other contact details (this may be your work or your personal contact details, depending on the nature of our relationship with you or the person for whom you work).
Data that we obtain from communications with us. We can process data that we obtain when you communicate with us, such as:
- Data about you that you provide when you communicate with us via telephone, email, our website, social media or in other ways.
- Data that you provide or that we obtain from you when you use our website, obtain goods or services or subscribe to them, when you provide us with goods or services, ask about a product, place an order, take part in a competition, promotion or survey, or contact us regarding an issue or do any of these things on behalf of the person for whom you work.
Data related to our relationship with you or the person for whom you work. We can process data related to our relationship with you or the person for whom you work, such as:
- Data related to the transactions that you or the person for whom you work make (for example, data about goods or services that we have provided you or the person for whom you work with, or that we have obtained from you or the person for whom you work).
- Other data related to you that we need to process in order to sign or execute a contract with you or the person for whom you work (for example, data on your working capacity and data obtained from bodies that provide credit references, should this be necessary in order to be able to carry out the pertinent checks in relation to the contracts with you or the person for whom you work or with whom you have a relationship of another kind).
- Data about events to which you or people related to you are invited, as well as preferences and personal data, to the extent that such data is useful for organising and managing these events (for example, dietary requirements).
- Data related to you that you provide us with or that we obtain in another way when you visit us (for example, if you sign in upon arrival or we record you whilst you visit us or you provide us with your vehicle registration plate data).
With whom can we share your personal data?
Any member of our organisation, i.e. our branch offices and commercial partners.
The relevant third parties, including:
- Our commercial partners, customers, suppliers and subcontractors for the execution of any operation that we agree to carry out and other relationships that we develop in the normal process of operations with you or the person for whom you work.
- Our auditors, legal advisers and other professional advisers or service providers.
- Bodies that provide credit references with the aim of assessing your credit score in the context of entering into a contract with you or the person for whom you work.
In relation to data obtained via our website:
- Our sales networks, who need this data in order to select and offer you content that is relevant for you and others.
- Search engine and analytics providers (including A/B testing tools) that help us improve and optimise our website, in compliance with the cookies section of this policy.
Other possible disclosures.
We can disclose your personal data to third parties:
- If a third party acquires us or acquires all or a substantial part of our assets, in which case the personal data that said substantial part has about its customers will be one of the transferred assets.
- If we are obliged to disclose or share your personal data in order to comply with a legal obligation or to enforce or apply our terms of supply and other agreements with you; or to protect the rights, property or safety of Distribuciones Suner, its customers or others. This includes the exchange of data with other companies and organisations with the aim of preventing fraud and reducing the credit risk.
What is the legal basis for processing your personal data?
The legal basis on which we process your personal data is the following:
When it is necessary to obtain your prior consent to process your data, we will obtain your consent and we will use this as the basis for the data processing in question (see below for how to withdraw your consent at any time).
In any other case, we will process your personal data when the processing is necessary:
for executing an operation you are a part of or to take measures upon your request before formalising said operation;
to comply with a legal obligation that affects us, or
to comply with our legitimate interests or those of another person, only in circumstances in which these legitimate interests are not cancelled out by your interests or rights and fundamental freedoms for the protection of personal data (most cases in which we process your personal data regarding a relationship that we have with the person for whom you work will fall under this category).
Where do we process personal data?
The data we process in relation to you may be transferred or stored outside of the European Economic Area (EEA), in a place that may not have an equivalent data protection law. Personnel that are located outside of the EEA who work for us or for one of our suppliers may also process this data. This includes personnel who participate, among other things, in order delivery, the processing of payment information and the provision of support services.
All personal data that we process is stored securely. All payment transactions will be encrypted using the appropriate technology. When we have provided you with (or you have chosen) a password that allows you to access certain parts of our website or systems, you will be responsible for maintaining the confidentiality of this password. Please do not share this password with anyone.
Unfortunately the transmission of information over the Internet is not entirely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of data that is transmitted to our website, so any transmission is at your own risk. Once we have received the information, we will adopt strict security procedures and measures to prevent unauthorised access.
How long do we process personal data for?
We only process personal data for the period of time necessary to fulfil the purpose or purposes for which they were originally collected. They will then be deleted or filed, unless we need to continue to process them to comply with our legal obligations or for other legitimate and legal purposes.
What are your rights?
You have the following rights with regard to your personal data that we process:
You can request access to the personal data in question (see the section on how to exercise your right of access to your personal data below).
You can request the rectification of any incorrect personal data that we process.
In certain circumstances (usually when you have provided the personal data and we no longer need to process it), you can request that we delete the personal data in question.
If we process your personal data based on your prior consent for this, you may withdraw that consent at any time, at which point the processing will stop.
If you have any complaint about our processing of your personal data, you can contact us or file a complaint with the Spanish Data Protection Agency.
How to withdraw your processing consent.
To withdraw your consent to the processing of your personal data:
Send us an email to email@example.com
Write to us at the address below.
How to exercise your right to access your personal data.
To exercise your right to access your personal data:
Send us an email to firstname.lastname@example.org
Write to us at the address below.
Remember we may have to ask you for more information to confirm your identity before giving you the information requested.
Our contact details.
Our full details are:
Distribuciones Suner S.L.U.
Polígono Comarca 2 C/ B nº 13
31191 Barbatáin (Navarra)
Contact: Abel Gómez
Telephone no.: 948317347
The Spanish Data Protection Agency.
The Spanish Data Protection Agency is the supervisory authority in Spain and can provide you more information about your rights and obligations in relation to your personal data, as well as deal with any complaint you have about our processing of your personal data.
Changes to this policy.
Date of this policy.
This policy was last updated on 23 May 2018.