SAMMY FREE S.A.U. informs you of its Privacy Policy regarding the processing and protection of personal data of users that may be collected while browsing through the website https://sammyfree.eu.

In this regard, SAMMY FREE S.A.U. guarantees compliance with current legislation on the protection of personal data, reflected in the Organic Law 3/2018, of 5 December, on the Protection of Personal Data and the Guarantee of Digital Rights (LOPD GDD). It also complies with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons (GDPR).

Use of this website constitutes acceptance of this Privacy Policy.

Identity of the person responsible

• Data Controller: SAMMY FREE S.A.U.
  NIF: A98464381
  Address: C/ Núñez de Balboa, nº 114, piso 3, despacho 15 – 28006 Madrid – Spain.
  E-mail: admin@avalesconcursos.es
  Website: https://sammyfree.eu

Principles applied in data processing

In processing your personal data, the Data Controller shall apply the following principles which are in line with the requirements of the new European Data Protection Regulation (GDPR):

• Principle of legality, fairness and transparency: The Data Controller will always require consent for the processing of personal data, which may be for one or more specific purposes about which the Data Controller will inform the User in advance with full transparency.
• Principle of data minimisation: The Data Controller shall request only the data strictly necessary for the purpose(s) for which the data is requested.
• Principle of limitation of the retention period: The Data Controller shall keep the personal data collected for the time strictly necessary for the purpose(s) of the processing. The Data Controller will inform the User of the corresponding retention period according to the purpose. In the case of subscriptions, the Data Controller will periodically review the lists and remove those registrations that have been inactive for a considerable period of time.
• Principle of integrity and confidentiality: The personal data collected will be processed in such a way that their security, confidentiality and integrity are guaranteed.

The Data Controller takes the necessary precautions to prevent unauthorised access or misuse of its users’ data by third parties.

Collection of personal data

You do not need to provide any personal data to browse https://sammyfree.eu.

The cases in which you do provide your personal data are as follows:

• When commenting on an article or a page.
• By signing up for a subscription form or newsletter that the Data Controller manages with MailChimp.
• By signing up for a subscription form or a newsletter that the Data Controller manages with SendinBlue.

Rights

The Data Controller informs you that he/she has the right to:

• Request access to stored data.
• Request a rectification or cancellation.
• Request the restriction of their processing.
• Oppose processing.
• Request the portability of your data.

The exercise of these rights is personal and must therefore be exercised directly by the interested party, requesting it directly from the Data Controller, which means that any customer, subscriber or collaborator who has provided their data at any time may contact SAMMY FREE S.A.U. and request information about the data it has stored and how it was obtained, request its rectification, request the portability of their personal data, oppose its processing, limit its use or request the cancellation of such data in the files of the Data Controller.

To exercise your rights of access, rectification, cancellation, portability and opposition, please send an e-mail to admin@avalesconcursos.es together with valid legal proof such as a photocopy of your ID card or equivalent.

You have the right to effective judicial protection and to lodge a complaint with the supervisory authority, in this case the Spanish Data Protection Agency, if you consider that the processing of personal data concerning you is in breach of the Regulation.

Purpose of the processing of personal data

When you connect to the website to send an email to the Owner, write a comment on an article or a page, or subscribe to the newsletter, you are providing personal information for which SAMMY FREE S.A.U. is responsible. This information may include personal data such as your IP address, first and last name, physical address, email address, telephone number, and other information. By providing this information, you consent to the collection, use, management and storage of your information by – Startgo Connection S.L. – Startgo Connection S.L

The personal data and the purpose of the processing by the Data Subject is different depending on the information capture system:

• Comment forms: The Data Controller requests personal data, which may include: name and surname, e-mail address, and website address, in order to respond to Users’ comments.
• Content subscription forms: The Data Controller requests the following personal data: name and surname, e-mail address, telephone number and website address to manage the subscription list, send newsletters, promotions and special offers. The personal data provided to the Data Controller will be located on the servers of The Rocket Science Group LLC d/b/a, domiciled in the USA. (Mailchimp).

There are other purposes for which the Data Controller processes personal data:

• To ensure compliance with the conditions set out in the applicable law. This may include the development of tools and algorithms to help this website ensure the confidentiality of the personal data it collects.
• To support and improve the services offered by this website.
• To manage social networks. SAMMY FREE S.A.U. has a presence in social networks. If you become a follower on the Holder’s social networks, the processing of personal data will be governed by this section, as well as by those conditions of use, privacy policies and access regulations that belong to the social network that applies in each case and that you have previously accepted.

You can consult the privacy policies of the main social networks by following these links:

• Facebook
• Twitter
• Linkedin
• YouTube
• Instagram

The Data Controller will process your personal data in order to correctly manage your presence on the social network, inform you of its activities, as well as for any other purpose that the regulations of the social networks allow.

Under no circumstances will the Data Controller use the profiles of followers on social networks to send advertising on an individual basis.

Security of personal data

To protect your personal data, the Data Controller takes all reasonable precautions and follows industry best practices to prevent the loss, misuse, improper access, disclosure, alteration or destruction of your personal data.

The website is hosted by 1&1 IONOS España S.L.U. Data security is guaranteed, as they take all necessary security measures. You can consult their privacy policy for more information.

Content from other websites

Pages on this website may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in exactly the same way as if you had visited the other website.

These websites may collect data about you, use cookies, embed additional tracking code from third parties, and monitor your interaction using this code.

Cookie Policy

In order for this website to function properly it needs to use cookies, which is information that is stored in your web browser.

Legitimation for data processing

The legal basis for the processing of your data is: consent.

To contact the Data Controller, subscribe to a newsletter or make comments on this website you must accept this Privacy Policy.

Categories of personal data

The categories of personal data processed by the Data Controller are:

• Identifying data.

Retention of personal data

The personal data you provide to the Data Controller will be retained until you request its deletion.

Recipients of personal data

• Mailchimp The Rocket Science Group LLC d/b/a, domiciled in the USA. More information at: https://mailchimp.com The Rocket Science Group LLC d/b/a processes the data for the purpose of providing email marketing services to the Data Controller.
• SendinBlue, a simplified joint stock company (société par actions simplifiée) registered in the Paris Trade and Companies Register under number 498 019 298, having its registered office at 55 rue d’Amsterdam, 75008, Paris (France). More information at: https://es.sendinblue.com SendinBlue processes the data for the purpose of providing solutions for sending emails, transactional SMS and marketing SMS to the Data Controller.
• Google Analytics is a web analytics service provided by Google, Inc., a Delaware company headquartered at 1600 Amphitheatre Parkway, Mountain View (California), CA 94043, United States (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help the Data Controller analyse how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. More information at: https://analytics.google.com
• Google AdSense is a set of advertising services provided by Google, Inc., a Delaware corporation with its principal place of business at 1600 Amphitheatre Parkway, Mountain View (California), CA 94043, United States (“Google”). AdSense uses cookies to improve advertising, target advertising based on content that is relevant to users and improve campaign performance reporting.More information at: https://www.google.com/adsense

Google’s Privacy Policy page explains how Google manages privacy with respect to the use of cookies and other information.

You can also see a list of the types of cookies used by Google and its partners and information about their use of advertising cookies.

Web browsing

When browsing https://sammyfree.eu non-identifying data may be collected, which may include, IP address, geolocation, a record of how services and sites are used, browsing habits and other data that cannot be used to identify you.

The website uses the following third-party analysis services:

Google Analytics.

Google AdSense.

The Data Controller uses the information obtained to obtain statistical data, analyse trends, administer the site, study browsing patterns and to gather demographic information.

The Data Controller is not responsible for the processing of personal data by websites that can be accessed through the various links contained in the website.

Accuracy and veracity of personal data

You undertake to ensure that the data provided to the Data Controller is correct, complete, accurate and up to date, as well as to keep it duly updated.

As a user of the website you are solely responsible for the accuracy and correctness of the data submitted to the website exonerating SAMMY FREE S.A.U. from any liability in this regard.

Acceptance and consent

As a User of the Web site declares to have been informed of the conditions on the protection of personal data, accepts and consents to the processing of such data by SAMMY FREE S.A.U. in the manner and for the purposes indicated in this Privacy Policy.

Revocability

To exercise your rights of access, rectification, cancellation, portability and opposition, please send an e-mail to admin@avalesconcursos.es together with valid legal proof such as a photocopy of your ID card or equivalent.

The exercise of these rights does not include any data that SAMMY FREE S.A.U. is obliged to keep for administrative, legal or security purposes.

Changes to the Privacy Policy

The Data Controller reserves the right to modify this Privacy Policy to adapt it to new legislation or jurisprudence, as well as to industry practices.

These policies shall remain in force until amended by other duly published policies.