Who is responsible for processing your data?

For what purpose do we process your personal data?

TRUCK AND WHEEL AUTOMOTIVE, S.L. processes the information provided by data subjects in order to manage the personal data necessary to provide the requested services or products. TRUCK AND WHEEL AUTOMOTIVE, S.L. will also process the data to carry out administrative, accounting and tax management, as well as to send you commercial communications about our products and services.

GDPR Legal Bases:

• GDPR 6.1(a): The data subject has given consent for one or more specific purposes: sharing data with companies necessary for the requested service, sharing data with third-party applications, sending commercial promotions.
• GDPR 6.1(b): Processing necessary for the performance of a contract or pre-contractual measures at the request of the data subject.
• GDPR 6.1(c): Processing necessary for compliance with a legal obligation applicable to the controller.
• GDPR 6.1(f): Processing necessary for the purposes of legitimate interests pursued by the controller or a third party, provided such interests are not overridden by the rights or freedoms of the data subject.

How long will your data be kept?

Your data will be kept for as long as necessary to fulfil the purpose for which it was collected and to determine any potential liabilities arising from that purpose or the processing.
For purposes requiring express consent, the data will be kept until you exercise your right of erasure or restriction—e.g., the sending of commercial communications.

What is the lawful basis for processing your data?

Le indicamos la base legal para el tratamiento de sus datos:

• Performance of a contract: Purchase/sale or supply of our products and/or services.
• Consent: Sending commercial communications about our products and services.
• Compliance with legal obligations: Processing necessary to comply with a legal obligation applicable to the controller.
• Legitimate interest of the controller: Purposes related to the provision, support and communication of contracted products/services (customer service, returns, transportation, coordination with third parties, offers, claims management, etc.). Administrative, accounting and tax management; communications with clients; sharing data with group companies for legitimate-interest purposes.

To whom will your data be communicated?

• Public administrations with jurisdiction in the matter, for compliance with legal obligations.
• Social Security Treasury and other public bodies.
• Individuals or organisations providing external services to the controller: consultancy, IT services, auditors, insurance companies, occupational risk prevention, lawyers, and other service providers.
• Financial institutions for economic transactions.
• Third-party processors providing services to TRUCK AND WHEEL AUTOMOTIVE, S.L. with the required GDPR-compliant agreements.

Are data transfers to third countries anticipated?

No international data transfers are anticipated.

What are your rights when you provide your data?

Any person has the right to obtain confirmation as to whether TRUCK AND WHEEL AUTOMOTIVE, S.L. is processing personal data concerning them.
Data subjects have the right to access their personal data, request rectification of inaccurate data or request deletion when the data is no longer necessary for the purposes collected.

In certain circumstances, you may request restriction of processing, in which case we will only keep the data for the exercise or defence of claims.
In certain circumstances and for reasons related to your particular situation, you may object to processing. TRUCK AND WHEEL AUTOMOTIVE, S.L. will cease processing unless there are compelling legitimate grounds or for defence of legal claims.

You may exercise your rights by emailing dpo@tw-group.com or writing to:
Pol Arazuri-Orcoyen Calle E, Parcela 2.3 (Arazuri), 31170 Navarra.

If you have granted consent for a specific purpose, you may withdraw it at any time, without affecting the lawfulness of processing carried out before the withdrawal.

If you believe your rights regarding data protection have been violated, especially if you have not been satisfied in the exercise of your rights, you may lodge a complaint with the competent Data Protection Authority:
www.aepd.es.

What rights do you have?

• To know whether we are processing your data.
• To access your personal data.
• To request rectification if your data is inaccurate.
• To request deletion if your data is no longer necessary or if consent is withdrawn.
• To request restriction of processing in certain circumstances.
• To data portability in a structured, commonly used, machine-readable format. We can also send it directly to another controller when technically feasible.
• To lodge a complaint with the Spanish Data Protection Agency if you believe your request has not been properly addressed.
• To withdraw consent at any time.

If you change your data, please notify us so we can keep it updated.

Do you want a form to exercise your rights?

We have forms available for exercising your rights. Request them by email, or you may use those provided by the Spanish Data Protection Agency.
Forms must be electronically signed or accompanied by a copy of your ID.
If someone represents you, they must attach a copy of their ID or sign electronically.
Forms may be submitted in person, by mail or email to the Data Controller at the address listed above.

How long will it take to respond to your request?

Depending on the right exercised, we will respond within one month, extendable to two months if the request is unusually complex.

How did we obtain your data?

The personal data processed by TRUCK AND WHEEL AUTOMOTIVE, S.L. originate from the data subject.
The categories of data processed are:

• Identification data: DNI/NIE, full name, phone number, image, voice, address, signature, email address.
• Other data: personal characteristics, education/professional information, commercial information, transactions of goods and services, bank details.
• Commercial information.
• No special categories of personal data are processed (data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, genetic or biometric data for unique identification, health data, or sexual life/orientation).