Política de Privacidad
We (also referred to as "We", "Us", or "Our") are committed to protecting your Personal Data and privacy.
This Privacy Policy explains how we collect and store information you provide through the https://sufraganza.com website (the Sufraganza).
The following principles apply:
We want you to have all the information you need to make informed decisions about how your Personal Data is used and processed. We use a variety of methods to provide you with relevant information, and where we determine that specific details are required, we will provide them at the appropriate time. We're happy to answer any questions you may have about the limitations established by law.
1. ¿El alcance?
Esta política describe los Datos Personales que Sufraganza recopila sobre personas naturales y cómo los procesa, comparte con terceros y protege.
Esta Política se refiere a la información relacionada con una persona natural identificada o identificable. Una persona natural identificable es aquella que puede ser reconocida de forma directa o mediante la combinación de información adicional que poseemos o a la que tenemos acceso.
A los efectos de esta Política, "procesamiento" comprende cualquier operación que implique el uso o la recopilación de Datos Personales, incluyendo su gestión, estructuración y almacenamiento.
Nuestros servicios están dirigidos al público general y no están diseñados para personas menores de 18 años. No buscamos ni recopilamos conscientemente información de menores de 18 años, ni les permitimos utilizar nuestros servicios. Si tomamos conocimiento de que poseemos información de un menor, procederemos a eliminarla a la brevedad posible.
2. What personal data do we hold about you?
When you access our services, service channels, or website, we collect Personal Data. In some cases, we may ask you to provide it directly. In others, we collect Personal Data by analyzing how you use our Services or service channels, or by receiving your information from our external partners.
3. There is no requirement to disclose personal information to the company, nor any consequences for choosing not to do so.
You are not required to provide us with personal data. In certain circumstances, withholding personal data may prevent us from delivering the Services or from granting you access to the website.
4. What types of personal data may we collect? When you visit our website, we will collect the following personal data from you:
This includes information about your online activity log, traffic data (such as your IP address, access date, and access time), language preferences, software crash logs, browser type, and device details. The information collected is non-personal and cannot be used to identify you.
Personal data you provide to us: any personal data you voluntarily share when connecting to a third-party online trading platform through us.
Personal information you provide directly to third-party platforms to facilitate transactions: this includes your full name, address, phone number, and email address.
5. Legal Basis and Grounds for Personal Data Processing
Sus Datos Personales son procesados por la Compañía para los fines descritos en esta sección, conforme a la base legal aplicable en cada caso.
Sin una base legal válida, la Compañía no puede utilizar sus Datos Personales. Los fundamentos legales sobre los cuales la Compañía puede procesar sus Datos Personales son los siguientes:
- You have provided consent for your Personal Data to be processed for one or more purposes. This applies when you submit personal information through the Website for transfer to a third-party trading platform.
- The Company or a third party may process data to pursue a legitimate interest — for example, to improve Our Services or to defend legal claims.
- Processing is required to comply with a legal obligation.
Reach out to us by email for details on the processing carried out to safeguard legitimate interests.
Below is a list of the purposes and legal bases under which we may use the Personal Data you provide to us.
Alcance, Base Legal
1. At your request, we may share your personal data with third-party companies to facilitate access to digital trading.
You have given your consent for your Personal Data to be processed for one or more specified reasons.
2. We use your personal data to respond to your requests, questions, and concerns related to our Services.
Processing is required to serve the legitimate interests of the Company or a third party.
3. Personal data is processed to meet applicable legal, administrative, and judicial obligations.
Processing is required to meet legal obligations.
4. To improve our Services, we may use personal data to optimize their performance. This includes crash reports and functionality error logs collected in connection with the Services.
Processing requires the Company's legitimate interests, or those of a third party.
5. To prevent fraud and misuse of Our Services
Processing is required to serve the legitimate interests of the Company or a third party.
6. To carry out and manage activities aligned with the requirements of Our Services. These include back-office functions, business development activities, strategic decision-making, and oversight mechanisms.
Processing is required to serve the legitimate interests of the Company or a third party.
7. We use statistical and other analytical techniques to inform decisions across a range of matters.
Processing is required to serve the legitimate interests of the Company or a third party.
8. To protect our rights, interests, and assets — as well as those of third parties — we may process your personal data to establish or defend legal claims, in accordance with applicable laws, regulations, agreements, and any terms or policies in effect.
Processing requires the Company's legitimate interests, or those of a third party.
6. Sharing Personal Data with Third Parties
The Company may share Personal Data with third-party service providers, including hosting and storage providers that process IP address information, as well as providers that analyze user experience.
You may also request that we share specific Personal Data about you with third-party trading platforms. In such cases, we will pass on the Personal Data you have provided to those platforms. Their use of your Personal Data is governed by their own privacy policies. Your Personal Data may be shared with multiple trading platforms.
The Company may share Personal Data with affiliated entities or business partners to support the improvement and optimization of its products and services.
Where necessary to protect the rights or assets of third parties, the Company is authorized to disclose Personal Data to regulatory, local, or other official authorities.
The Company may also share Personal Data with prospective investors or acquirers, or with lenders of the Company or any other entity within the group, in connection with any transaction involving the transfer or sale of Company or group assets, or as part of any merger, restructuring, consolidation, or insolvency proceeding involving the Company or any other business within the group.
7. Cookies and Third-Party Services
We may use third-party services, such as advertising providers and analytics companies, on our website. These third parties may also use cookies or similar technologies.
Cookies are small text files stored on your device when you visit or access the website. They collect information about your preferences and browsing behaviour to improve your user experience, remember your settings, and personalise products and services that may be relevant to you. Cookies are also used for statistical and analytics purposes.
Some cookies we use are session cookies. These are temporarily stored on your device and expire once you close your browser. Others are persistent cookies, which remain on your device for a set period after your browser is closed. Persistent cookies help the website recognise you as a returning user and allow you to pick up where you left off.
Tipos de Cookies:
They may be used by us according to their purpose.
1. Essential cookies only
These cookies are necessary to access the features you've requested and navigate our website. They enable your device to download and transmit data, allowing you to browse the site, use its features, and return to previously visited pages.
Cookies collect personal data such as your username and the date of your last login to verify site access. They are deleted when you close your web browser (session cookies).
2. Cookies de funcionalidad
Cookies let us recognize you each time you visit our site and save your preferences and settings.
Cookies collect personal data — including your username and last login date — to confirm your active session on the site. They are deleted automatically when you close your browser (session cookies).
3. Cookies de rendimiento
We use cookies to collect statistical data on site performance and to run analytics that help us improve your experience.
Las cookies almacenan datos anónimos no vinculados a ninguna persona identificable. Algunas se eliminan al cerrar el navegador; otras tienen validez indefinida.
Cookies are blocked or deleted
To block or delete cookies, you'll need to adjust your browser settings. Below you'll find links to help you through the process for some of the most widely used browsers.
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
Tenga en cuenta que si esto ocurre, algunas o todas las funciones del sitio web podrían no funcionar correctamente.
ONLINE TRACKING NOTICE
This service does not currently support Do Not Track signals.
8. Retention of Your Personal Data
The Company will retain your Personal Data for as long as necessary to fulfil the purposes described in this Policy, or for longer periods as permitted by applicable law, regulations, policies, or orders.
We will share your information with third-party trading platforms for a period of 12 months. If you consent to this, we will continue sharing your data for an additional 12 months.
We periodically review the Personal Data we hold to confirm it is no longer required.
9. Transfers of Personal Data to a Third Country or International Organization
Su información personal puede ser transferida a otros países, incluyendo a terceros países distintos al de su residencia, o a organizaciones internacionales. La Compañía adopta todas las medidas necesarias para proteger los Datos Personales que usted proporciona y garantizar que los usuarios puedan ejercer sus derechos y acceder a recursos legales efectivos.
Estas protecciones y salvaguardas están disponibles para todas las personas residentes en el EEE (Espacio Económico Europeo).
- Transferencia a un tercer país u organización internacional respecto del cual la Comisión Europea ha determinado que garantiza un nivel de protección adecuado para los Datos Personales transferidos, conforme al artículo 45(3) del Reglamento 2016/679 del Parlamento Europeo y del Consejo, de 27 de abril de 2016 (el "GDPR").
- La transferencia se realiza en virtud de un acuerdo jurídicamente vinculante y ejecutable entre entidades o autoridades públicas, conforme al Artículo 46(2)(a).
- This transfer was carried out in accordance with the standard contractual clauses for data protection adopted by the EU Commission under Article 46(2)(c) of the GDPR. The clauses adopted by the EU Commission are available at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.
The Company can provide information on the security measures used to protect your Personal Data when transferred to third countries or international organizations. To request this information, contact us at: info@sufraganza.com
10. Seguridad de Datos Personales
We have implemented appropriate organizational and technical measures to protect Personal Data, including safeguards against accidental or unlawful destruction, loss, or alteration.
We cannot guarantee that Personal Data will remain error-free at all times, nor can we be held liable for intangible, incidental, or consequential damages arising from the use or disclosure of Personal Data. This includes, without limitation, Personal Data disclosed due to transmission errors, unauthorized third-party access, or other causes beyond our control.
Where legal or other obligations outside our control require it, we may be compelled to disclose Personal Data to third parties, such as public authorities. In such cases, we cannot control the level of security those third parties apply to your Personal Data.
Personal Data cannot be transmitted over the internet with absolute security. The Company cannot guarantee the security of Personal Data you transmit to us online.
11. Hyperlinks to Third-Party Websites
Our website may contain links to third-party websites and applications. These sites and applications are not under our supervision, and we are not responsible for how they collect or process personal data. This Policy does not apply to actions taken through third-party sites or applications.
Before accessing or using any third-party website or application, we recommend reading its privacy policy carefully. We also encourage you to consider what personal data you share with these platforms.
12. Changes to This Policy
Antes de acceder a cualquier sitio web o aplicación de terceros, le recomendamos leer sus políticas de privacidad. Tenga precaución al proporcionarles cualquier Dato Personal.
13. Your rights regarding your personal information
You have the right to request that we verify the accuracy of the Personal Data we collect about you, correct any errors, and delete any Personal Data that is no longer necessary. You may also restrict the scope of how your personal information is processed.
If you are an EEA resident, please refer to this page:
These rights apply to the information you provide in connection with your Personal Data. To exercise any of these rights, please send a written request to the email address listed below.
Right of Access
We may verify the accuracy of the Personal Data being processed about you. If confirmed, you may access your Personal Data.
We will provide one electronic copy of your Personal Data currently being processed and may charge a reasonable fee for additional copies. Data will be made available electronically upon request.
The right of access to Personal Data must not conflict with the rights and freedoms of third parties. If a request would be prejudicial to another person's rights or freedoms, we may decline or limit our ability to fulfill it.
Right of Rectification
We may rectify inaccurate Personal Data. You have the right to request that incomplete Personal Data concerning you be completed, taking into account the purpose of the processing.
Right of Erasure
This right applies when: (a) the Personal Data is no longer necessary for the purpose for which it was collected or processed; (b) you withdraw your consent and no legal basis for processing exists; (c) you object, on grounds specific to your situation, to processing of Personal Data concerning you that is based on legitimate interests pursued by us or a third party; (e) the Personal Data is processed unlawfully; or (f) the Personal Data must be deleted to comply with a legal obligation.
This right does not apply where processing is necessary (a) to comply with a legal obligation requiring processing under European Union or Member State law; or (b) for the establishment, exercise, or defense of legal claims.
Restriction of Processing
If you question the accuracy of your Personal Data, you may request that we restrict its processing.
Where processing is restricted, Personal Data may only be retained with your consent, or for the establishment, exercise, or defense of legal claims, for the protection of another individual's rights, or where a significant public interest exists within the European Union or a Member State.
Right to Data Portability
Where processing is carried out by automated means and is based on your consent or a contract to which you are a party, you have the right to review the Personal Data you have provided to us.
You may request that your Personal Data be transferred directly from us to another controller, where technically feasible. Exercising your right to data portability does not affect your rights under the right of erasure. The right to data transfer does not interfere with the rights or freedoms