This document regulates the rules regarding the Privacy Policy on which the Company Translock IT SLU (hereinafter “Translock“) as Data Controller, will carry out the processing of the personal data of its customers (buyers or not of its services) and suppliers or third parties, provided by those during their access to the website in their registration process or provided by any other means valid in law valid in law.

If you expressly agree to the transfer of your data to Translock, whatever means you do so, provided that your consent is express, you will be deemed to be giving it in a free, informed, specific and unambiguous way to Translock to process your personal data, in accordance with the General Data Protection Regulation of the Parliament and of the Council 679/2016, of April 27 (hereinafter “GDPR”) and Organic Law 3/2018, of December 5, On Data Protection and Guarantee of Digital Rights.

Controller´s data:

Controller: Translock IT SLU

CIF: B88074703


Social Address: Calle Joaquin Montes Jovellar, 4 – 28002 Madrid

Registration Data: Registered in the Commercial Register of Madrid, volume 37683, folio 101, section 8, sheet M 671389

Email Address:

Translock may collect on its website the data of its customers, suppliers and other third parties (hereinafter collectively referred to as “the User” or “the Users”) when they access it and register or request their services through the contact link.

The User must enter all the data that the Platform requires at all times (especially those marked with an asterisk), because if not, he/she will not be able to complete his registration as a User or the use of certain functionalities or services available through that.


Data from Users will also be collected where by other means the Data Subjects have provided it to Translock, within the normal development of a commercial or professional activity.


In addition, the User shall ensure that the Personal Data provided is true and accurate and shall notify through the appropriate conduit any changes or modifications thereto.


In the event that the User provides data of third parties, he/she shall assume responsibility for having previously informed him/her and having his/her consent to it, in accordance with Article 14 of the GDPR).

Category of data collected

Translock may collect and process the following personal data of the User:

Identifying data of the user or their legal representatives; First and last name; NIF Contact details; Telephone number; Email and postal address; Company the User works for; Credit or debit card number; Bank account.

Recipients of the data

Those Interested Parties who perform services for Translock, related to the service that Translock provides to the User, or vice versa, will have access to the User’s data. Translock will maintain the corresponding custom processing contracts with each of the suppliers providing services to it, with the aim of ensuring that these providers will process your data in accordance with the provisions of current legislation.

Personal data may also be transferred to the competent authorities provided there is a legal obligation.

Likewise, they may be communicated to financial institutions through which the management of collections and payments is articulated.

They may also be transferred to third parties related to Translock’s activity, in order to send the User commercial information that might be of interest to him, always connected to the Translock business and provided that the User has expressly accepted it.

Purpose of the treatment

Translock will process personal data for the purposes set out below, depending on the reason for which they were provided to it:

Carry out the provision of the contracted services, the maintenance of the contractual relationship and the monitoring of the same.

Contact, process, manage and respond to the request, request, incident or query of the User (whether via email, contact form or telephone).

Manage, where appropriate, the User’s participation in the customer’s private area.

Manage, where appropriate, the sending of commercial communications about products and services marketed by Translock by electronic and/or conventional means.

Make, where appropriate, a User profile to offer you Translock-related products and services in accordance with your interests.

Assess and manage, where appropriate, the User-provided curriculum for selection processes that fit your professional profile and carry out the necessary actions for the selection and recruitment of staff.

Based on the above and depending on the category of User, Translock may give the data the following uses:


Budgeting Billing

Sending commercial communications

Updates of service conditions

Regular communication within the contracted service provision

Perform a professional profile for the offer of services



Sending commercial communications

Updates of terms of service

Usual communication within the provision of contracted services.


Social Media Contacts

Creating a followers community

Handling friend requests

Sending business information

Make a professional profile for the service offering

Service Conditions updates

Job applicants

Valuation of the data included in the curriculum to analyse the suitability to the needs of Translock

Sending relevant information related to the job sought in the organization

In case the User expressly accepts it, the data may be transferred to collaborating or related companies in order to help the User to get a job.

Information collected by the mobile applications

Our Services can be provided through the Mobile Application. We may collect and use technical data and related information, including but not limited to, technical information about your device, system and application software, and peripherals, that is gathered periodically to facilitate the provision of software updates, product support and other services to you (if any) related to such Mobile Applications.

When you use our Mobile Application, it may automatically collect and store some or all of the following information from your mobile device (Mobile Device Information), in addition to the Device Information, including without limitation: The manufacturer and model of your mobile device; Your mobile operating system; Information about how you interact with the Mobile Application and any of our web sites to which the Mobile Application links, such as how many times you use a specific part of the Mobile Application over a given time period; the amount of time you spend using the Mobile Application; how often you use the Mobile Application; actions you take in the Mobile Application and how you engage with the Mobile. This information allow us to personalize the services and content available through the Mobile Application

Legitimation for the collection and processing of data

The legal basis for the collection and processing of User data are, on the one hand, the mandatory obligation to be able to provide the contracted services and on the other, the consent expressly granted by the User for their collection and processing.

Duration of the treatment and conservation of the data

The data for the management of the relationship with the customer, for the billing and for the collection of the services will be kept while the contract is in force. Once this relationship is terminated, if applicable, the data may be kept for the time required by the applicable legislation and until they prescribe any responsibilities arising from the contract.

Data for the management of queries and requests will be kept for the time necessary to respond to them, with a maximum period of one year.

The data for the sending of commercial communications and commercial profiling of our products or services will be kept for as long as the commercial relationship with the User is maintained and does not withdraw their consent to this.

Resume data for selection processes will be retained for two years.

For information purposes, the legal time limits for the retention of information in relation to different matters are set out below







Labour or social security-related documentation

4 years

Article 21 of Royal Legislative Decree 5/2000 of 4 August approving the consolidated text of the Law on Violations and Sanctions in the Social Order

Accounting and tax documentation for commercial purposes

6 years

Art. 30 Commercial Code

Accounting and tax documentation for tax purposes

4 years

Articles 66 to 70 General Tax Law

Control of access to buildings

1 month

Instruction 1/1996 Spanish Data Protection Agency (AEPD)

Video surveillance

1 month

Guide of 26 November 2018 of the AEPD Organic Law 4/1997. Law 5/2014 of April 4, On Private Security


User´s rights:

Any User who provides their personal data to Translock may exercise the following rights:

Access, rectification, opposition, deletion, portability and limitation of processing, as well as reject the automated processing of personal data collected by the Controller.

In turn, every User shall have the right to withdraw at any time the consent he has given.

These rights may be exercised free of charge by the User, referring to the request that is specified in the request through the contact details contained in the link of Legal Notice.

The User has the right to revoke the consent given at any time for the sending of commercial communications, simply notifying Translock and informing he does not wish to continue receiving commercial communications. To do this, the User may revoke their consent by referring to their request through the contact details contained in the Legal Notice or by clicking the link “no more commercial communications”

The User has the right to file a complaint with the Spanish Data Protection Agency if he understands that the Controller has committed any type of breach in the processing of his data.


The Controller will not collect for himself, in any case, data of minors. Given the difficulty of checking the age of Users, it will be the holders of the parental authority or the guardianship of children under the age of 14, who must establish the control measures on the devices that minors may access to, in order to prevent them from improperly giving their data.

If the Controller has reliable knowledge at any time that a minor has accessed his/her platform and their data is being processed without the authorization of their legal representatives, will immediately unsubscribe from such User.

Security measures

The Controller undertakes to comply with the commitment of secrecy of personal data and its duty to keep it, processing the personal data of the User confidentially, adopting the necessary technical and organizational measures that guarantee the security of the data and prevent its alteration, loss, treatment or unauthorized access, taking into account the state of technology, the nature of the stored data and the risks to which they are exposed.

Changes to the privacy policy

The Responsible may modify its Privacy Policy in accordance with the applicable legislation at any time. In any case, any modification of the Privacy Policy will be duly notified to the User to be informed of the changes made in the processing of their personal data and, if the applicable regulations so require, the User can give their consent.