Introduction to SWER DEVELOPMENTS CORPORATION S.L.

At SWER DEVELOPMENTS CORPORATION S.L. (“we” or “us” or “our”), we are committed to protecting the privacy and personal data of our users, customers and suppliers. The services we offer through the website can only work if we collect, store, transfer, dispose of or otherwise use (“collect and use”) specific data relating to you (“personal data” or “data”). Personal data is any information relating to an identified or identifiable natural person, such as your name, date of birth, address or e-mail address.

This privacy policy describes what information we collect from you and for what purpose we collect and use it when you use the services we offer on the platform. It also contains important information about the protection of your data, in particular, the legal rights you have in this respect.

Some of the services on our platform are offered by third-party providers. When using these services, the data protection regulations of these external providers apply in addition to this data protection declaration. Before using such services, the external providers will probably request your permission in accordance with data protection law.

According to the applicable data protection laws, SWER DEVELOPMENTS CORPORATION S.L. is obliged to inform you about data processing, an obligation it fulfills within this privacy policy. This privacy policy and its sections are not intended as contractual clauses and do not form part of the general terms and conditions (GTC) as a contract entered into with registered users. According to the applicable data protection legislation, SWER DEVELOPMENTS CORPORATION S.L. may process information necessary for the performance of a contract with you or for the implementation at your request of pre-contractual measures (art. 6, paragraph 1, letter b) of the GDPR). References to GTC should always be understood as information on data processing (art. 13 and 14 of the GDPR) and never as clauses forming part of the GTC. By using the platform and our services, you are entering into a legally binding contract between you and SWER DEVELOPMENTS CORPORATION S.L., the terms of which are set out in the GTC.

Data Controller

The person responsible for the processing of your personal data is:

SWER DEVELOPMENTS CORPORATION S.L.
NIF: B16401572
Gran Vía de les Corts Catalanes 617
[Phone number]
[email]

Personal Data Collected

Information gathered

We may collect and process the following categories of personal data:

• Contact information (name, postal address, telephone, email).
• Payment information (credit card number, bank account details, transaction history).
• Account information (username, password, user preferences, shipping information, session information).
• Browsing and usage data of our website (IP addresses, browser type and operating system, pages visited and browsing time, cookie data).
• Any other information you voluntarily provide us with through our contact forms, user creation, surveys, etc.

Sensitive personal data

Generally, we do not collect sensitive personal data (e.g., health information, religion, ethnicity) unless it is necessary and with your explicit consent.

Personal data sources

We collect personal data from the following sources:

• Directly from you: when you make a purchase, register on our website, complete forms, participate in surveys, or communicate with us.
• From third parties:
  • Payment service providers: To process transactions.
  • Social networks: When you interact with our official profiles.
  • Other business partners: To help us improve and provide our services.

Purposes of Processing

We process your personal data to:

• Manage and process your orders and payments: Ensuring that you receive the products and services you have requested.
• Provide customer service and technical support: To resolve any problems or queries you may have.
• Send commercial and promotional communications: As long as we have your consent, we will keep you informed about offers and news.
• Improve our products and services: Through analysis and usage statistics, to offer you a better experience.
• Comply with our legal and regulatory obligations: By ensuring compliance with all applicable regulations.

Legitimizing Basis for Processing

Execution of the Contract

The processing of your data is necessary for the performance of the contract entered into between you and SWER DEVELOPMENTS CORPORATION S.L. when you create an account on our website, place an order through our Marketplace, and manage your relationship with our Customer Service. This includes:

• Processing and tracking your orders.
• Payment and billing management.
• Communicating with you about the status of your orders.
• Resolving any problems related to your purchases.

Legitimate Interest

SWER DEVELOPMENTS CORPORATION S.L. may have a legitimate interest in processing your personal data for various purposes. These include:

• Sending emails announcing new sales and promotions to our members.
• Preventing and combating fraud on our website.
• Handling product returns and complaints.
• Recovering unpaid orders.
• Analyze our members’ browsing and behavior to improve our offers and services.

Consent

We process your personal data after obtaining your express consent. You may withdraw your consent at any time. Situations that require your consent include:

• Sending brand alerts and notifications.
• Linking your bank card details to your account to facilitate future orders.
• Creating a commercial profile based on data obtained from your browsing of the site.

Compliance with Legal Obligations

SWER DEVELOPMENTS CORPORATION S.L. is obliged to process your personal data in order to comply with various legal and regulatory obligations. This may include:

• Product recall or collection procedures.
• Accounting and tax management of your orders.
• Compliance with legal requirements of competent authorities.

Recipients of your Personal Data

SWER DEVELOPMENTS CORPORATION S.L. employees are responsible for processing your personal data. We ensure that only authorized persons have access to your personal data and only when it is necessary for the management of our business relationship or to comply with our legal obligations as long as it is permitted under applicable laws. We implement strict internal policies and access controls to ensure that your data is protected and used appropriately and securely.

We may also need to communicate your personal data to:

Subsidiaries and Subcontractors

We may communicate your personal data to our affiliates and subcontractors for the following purposes:

• Order management and shipping: Subcontractors that handle logistics and delivery of products (detail).
• Fraud prevention: Companies that provide security and fraud prevention services (please specify).
• Marketing and commercial prospecting: Suppliers that assist in advertising and marketing campaigns (detail).
• Customer service: Companies that provide customer service and support (detail).

Business Partners

(detail)

Payment Service Providers

(detail)

SWER DEVELOPMENTS CORPORATION S.L. may also be obliged to communicate your data to third parties in order to comply with legal, regulatory or conventional obligations or to respond to requests from legally authorized authorities.

International Data Transfers

In some cases, your personal data may be transferred to countries outside the European Economic Area (EEA). In such cases, we will ensure that such transfers are carried out with adequate safeguards in accordance with the GDPR.

(detail, if already possible)

Retention of Personal Data

We will retain your personal data only for as long as necessary to fulfill the purposes for which it was collected and in accordance with our legal obligations.

Retention Periods

• User accounts: The data associated with your account will be retained for as long as you keep your account active. If you decide to close your account, we will delete your data, unless we are required by law to retain it.
• Orders and transactions: We retain your order and transaction data for as long as necessary to comply with tax and accounting obligations.
• Marketing communications: Data used to send you marketing communications will be retained until you unsubscribe or withdraw your consent.
• Customer Support: Records of communications with customer support are retained for as long as necessary to handle your inquiries or complaints.

Conservation Criteria

• Legal obligations: We retain your information when we are required to do so by law, for example, to comply with tax, accounting or fraud prevention regulations.
• Dispute resolution: If it is necessary to retain your data to resolve a dispute or enforce our agreements, we will retain it until the dispute is resolved or the agreement is enforced.
• Legitimate Interests: In certain cases, we may retain your information for a longer period if necessary to protect our legitimate interests, such as fraud prevention.

Data Elimination

Once the data is no longer needed for the purposes for which it was collected and we are no longer required by law to retain it, we will securely delete it.

Elimination Request

You have the right to request deletion of your personal data at any time. We will evaluate your request and, if we are not legally obliged to retain the data, we will proceed with the elimination.

User Rights

You have the following rights in relation to your personal data:

Right of Access

You have the right to obtain confirmation as to whether we are processing your personal data and, if so, to access it. This includes information about the purposes of the processing, the categories of data, the recipients, and the retention period.

Right of Rectification

You have the right to request rectification of inaccurate or incomplete personal data that we hold about you. This ensures that the information is accurate and up to date.

Right of Deletion (Right to be Forgotten)

You have the right to request the deletion of your personal data when they are no longer necessary for the purposes for which they were collected, or when you withdraw your consent and there are no other legitimate grounds for the processing.

Right to Limitation of Processing

You may request to limit the processing of your personal data in certain circumstances, such as when you contest the accuracy of the data or object to the processing.

Right to Data Portability

You have the right to receive your personal data in a structured, commonly used and machine-readable format and to transmit it to another data controller without hindrance from us.

Right of Opposition

You may object to the processing of your personal data at any time, on grounds relating to your particular situation, where the processing is based on our legitimate interests or in the public interest.

Right to Withdraw Consent

You have the right to withdraw your consent at any time for those processing operations based on your consent. Withdrawal of consent will not affect the lawfulness of the processing based on the consent prior to its withdrawal.

Exercise of Rights

To exercise these rights, you can contact us using the contact details provided. We will evaluate each request and respond within the legally established deadline of one month. This deadline may be extended for an additional two months if necessary, taking into account the complexity and number of requests. In such a case, we will inform you of the extension within the first month and explain the reasons for the delay.

Personal Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure or destruction.

Cookies Policy

We use cookies and similar technologies to enhance your experience on our website. Cookies are small text files that are stored on your device when you visit a website. Cookies allow a website to remember your actions and preferences (such as login, language and other settings) over a period of time, so you don’t have to reset them each time you return to the site or navigate from one page to another.

Why are cookies used?

• To provide a correct functioning of our Platform
• Improve the speed/security of the Platform
• Identify you when you return to our Platform. This helps us to personalize our content and assess your preferences (so-called “functionality cookies”).
• Identify the number of people who visit our Platform and their behavior while on the Platform. This helps us to improve the performance of our Platform, for example, by ensuring that users can find what they are looking for (so-called “analytics/performance cookies”)
• They record your visit to our Platform, as well as which pages you browse and which links you click on. We use this information to better tailor our Platform, as well as the advertising we show you, to your interests. If you give us permission to send you e-mails, we will use this information to send you personalized marketing e-mails (so-called “behavioral targeting cookies”)
• They allow you to share pages on social networks such as Facebook or Instagram (called “tracking and plug-in cookies for sharing social content”, usually within the category of behavioral targeting cookies).

Types of Cookies Used

Type of Cookie	Description
Essential Cookies	Necessary for the basic operation of the web.
Performance Cookies	Used to collect data on the use of the website.
Functionality Cookies	They allow you to remember your preferences and settings.
Advertising Cookies	Used to display ads relevant to you.

Third Party Cookies

We may allow third parties, such as advertising networks or analytics service providers, to place cookies on our website. These cookies are managed by these third parties and we have no direct control over their operation.

Management of Cookies

When you access the Platform for the first time, use it after a long period of time or browse our website in incognito mode, you will see a cookie notification in the window and you will need to accept all cookies or set your preferences, choosing the type of cookies you would like to install on your device. You can manage your cookie preferences through your browser settings.

Please note that disabling some cookies may affect the functionality of our website.

Types of Cookies

Type	Description	Example
Session Cookies	They are deleted when the browser is closed.	Temporary storage of user session.
Persistent Cookies	They remain on your device until they expire or you delete them.	Remember user preferences, such as the selected language.
Proprietary Cookies	Placed by our website.	Personalization of the content according to your navigation.

Purpose of Cookies

• Improved User Experience: Personalization of content and recommendations based on your navigation.
• Analytics and Statistics: Collecting data to understand how our website is used and improve its performance.
• Personalized Advertising: Display relevant ads based on your interests and online behavior.

Changes in the Data Protection Policy

We reserve the right to modify this privacy policy at any time in accordance with applicable regulations . All changes will be posted promptly on this page. Notwithstanding the foregoing, you should check this page regularly for updates.

Contact

If you have any questions or concerns about our data protection and cookie policy, please do not hesitate to contact us at:

[Contact email]