Privacy Policy - USA Group

Privacy Policy

Who is responsible for precessing your data?

Company name: UGARTEBURU SA
C.I.F./N.I.F.: A20036088
Registered office: Polígono Industrial Goitondo Behekoa s/n, 48269 Mallabia (Bizkaia)
Registered in the Bizkaia Trade Register, sheet -BI 2233, Page -178, Tome -1900, Section -8, first entry.
Phone: +34943171512

For what purpose do we process your personal data?

In accordance with the provisions of EU Regulation 679/2016 and Organic Law 3/2018, of 5 December, on the protection of personal data and the guarantee of digital rights, we inform you that the personal data you provide us with, as well as those generated during the development of the relationship with you, will be processed for the following purposes
– To deal with your requests.
– To provide you with information on UGARTEBURU SA products, by consenting to the sending of commercial communications by e-mail or other equivalent electronic means of communication (such as SMS) that you have provided to us.
– To allow you to participate in prize draws or commercial promotions.
– If you send us a CV, so that we can consider your application as part of the recruitment process.
– To send you communications, by any means that you may have provided to us, relating to the activities of the Company that may be of interest to you.
– To respond to your requests, complaints and suggestions and to carry out any communication activity.
– The accounting, fiscal and administrative management of the entity.

How long will we keep your data?

The personal data provided will be kept for as long as is necessary to achieve the purposes for which they were collected or recorded, including the need to keep them for the duration of any applicable or relevant limitation periods, unless the data subject or their legal representative requests their cancellation and this is appropriate.

The retention of the data will be subject to the legal obligation that UGARTEBURU SA has to keep them. At the end of these periods, the data will be destroyed or erased, and the deletion, erasure or destruction will be carried out in such a way that the information contained in the media cannot be recovered.


The legal basis for the processing of your data is the consent given by the data subject. This consent is obtained expressly and unambiguously by filling in and, where applicable, sending the paper or electronic documents and forms in which your data are collected. All the documents used by the company to collect data for different purposes contain information clauses in accordance with the provisions of the Data Protection Code and the consent is expressly given by the data subject by signing them or sending the forms on the website.
The processing is also legitimate when it is necessary for the performance of a contract or the provision of a service to the data subjects to which they are parties, or for the application of pre-contractual measures at their request (art. 6.1.a and b RGPD).
UGARTEBURU SA may also process personal data in order to comply with legal obligations and to satisfy legitimate interests, provided that the interests and fundamental rights of the data subject are not overridden.

Will your information be shared?

Your information will not be disclosed to any entity without your consent, except as required by law. In this sense, your explicit consent will be requested for the communication of your data to any other entity.
As a result of the management of the authorised purposes, your data may be communicated to entities or persons directly related to UGARTEBURU SA and the services provided by the same. Likewise, your personal data will be made available to public administrations, magistrates and courts, in order to inform them of any obligations that may arise from the processing, provided that such communications are protected by law.
Your data may also be transferred to companies that provide us with consultancy, IT maintenance, marketing, training or auditing services. These companies will only have access to the personal information necessary to perform these services and will be required by a “data processing contract” to maintain confidentiality, not to use the information for other purposes, and to take measures to ensure the integrity and availability of the information.
There is no international transfer of data outside the European Union or to entities that do not comply with the data protection standards set out in EU Regulation 679/2016.

Where does your data come from?

The personal data processed by UGARTEBURU SA is provided by the data subject or is obtained from public sources.

What types of data does UGARTEBURU SA process?

UGARTEBURU SA processes the data that you provide us with, which may fall into the following categories
– Identification and contact details
– Academic and professional data
– Employment data
– Economic, financial and insurance data
– Commercial information

What are your rights?

Any person has the right to obtain confirmation as to whether or not UGARTEBURU SA is processing their personal data.

Interested parties have the right to access their personal data and to obtain a copy of the personal data being processed, to update it and request the rectification of inaccurate data or, where appropriate, request its deletion when, among other reasons, it is no longer necessary for the purposes for which it was collected.

In certain circumstances and for reasons relating to their particular situation, data subjects may oppose the processing of their data. UGARTEBURU SA will stop processing the data, except for legitimate reasons or for the exercise of possible claims.

Also, in certain circumstances provided for in article 18 RGPD, the data subject may request the limitation of the processing of their data, in which case UGARTEBURU SA will process them, with the exception of their storage, with the consent of the data subject or for the formulation, exercise or defence of claims, or for the protection of the rights of another natural or legal person, or for reasons of public interest of the Union or of a specific Member State.

As a consequence of the application of the right to erasure or to object to the processing of personal data in the online environment, data subjects have the right to be forgotten according to the case law of the Court of Justice of the EU.

Under the right to portability, data subjects have the right to obtain personal data concerning them in a structured, commonly used and machine-readable format and to have it transferred to another controller.

Every data subject has the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her, subject to the exceptions provided for in Article 22(1) of the GDPR.

The data subject has the right to have his or her data deleted because the purpose for which the data were processed or collected has ceased to exist, because consent has been revoked if it is the consent that legitimises the processing, or for the other reasons set out in Article 17 GDPR. Erasure will be carried out by proceeding to the high-level erasure of data contained in automated media, and the physical destruction of non-automated media.

How can rights be exercised?

In writing, always accompanied by a copy of the National Identity Card or any other document proving the identity of the interested person, to the addresses indicated in the heading.

What are the complaint procedures?

If you consider that your rights have not been duly respected, you have the right to lodge a complaint with the Spanish Data Protection Agency, whose contact details are Telephone: 901 100 099 / 9126 63 517. Postal address: C/ Jorge Juan, 6 Madrid.