Sunhero knows that your privacy is important to you, and we want you to know that it is important to us too. At any moment, the user can contact us to ask their questions and exercise their rights to access, correct, delete their data by sending an email to contact@sunhero.com.
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This Privacy Policy below describes the personal data we collect, how it’s used and shared, and your choices regarding this data. In this sense, you will find information regarding:

1. Which principles apply to the processing of your personal data.
2. Who the responsible for the processing of your data is.
3. What requirements you must meet to provide us with your personal data.

4. What data processing we carry out through the website and what their main characteristics are, explaining:

   • What data we collect and how we collect it.
   • For what purposes we collect the data we request from you.
     
   • What the legitimacy for the processing is.
     
   • How long we keep them.
     
5. To which recipients your data is communicated.
6. Existence of international transfers of your data.
7. What your rights are and how you can exercise them.
8. How we protect your personal information.
9. What legislation affects this policy.
10. Changes to this policy.

1. PRINCIPLES OF THE DATA PROCESSING

Our commitment to Privacy is one of our priority areas to improve trust and transparency with all those with whom we are linked. For this reason, we are guided by the principles included in Regulation (EU) 2016/679 General Data Protection, committing to:

• Process data in a responsible, fair, and transparent manner.
• Use data for determined clear and legitimate purposes.
• Only use data suitable, appropriate, and limited to each purpose.
• Use accurate and updated data.
• Keep data only for the necessary time.
• Guarantee the integrity and confidentiality of data.
• Act with proactive responsibility.

Sunhero complies with current legislation on data protection and monitors the correct use and processing of personal information. The intended purpose of the requested information is detailed on each form that records personal information.

2. WHO IS THE CONTROLLER OF YOUR PERSONAL DATA?

Your personal data will be processed by Sunhero Spain SL, with VAT B05334925 (hereinafter, “Sunhero”, “We”, “Our”, “Us”). Its contact information is as follows:

Address: C/ Tuset 19, 2-3 - 08006 Barcelona, Spain
Telephone no.: +34 919 01 25 13
Email:contact@sunhero.com

3. WHAT REQUIREMENTS MUST YOU MEET IN ORDER TO PROVIDE US WITH YOUR PERSONAL DATA?

3.1. Minimum age. In order to provide us with your personal data, you must be at least 14 years of age. However, take into account that this Website is intended for persons of legal age.

3.2. Truthfulness. When you provide us with your data to use our services, you guarantee that the data and information provided is real, truthful, updated and also belongs to you and not to third parties.

Furthermore, you must notify us of any modification that may occur in the data provided, and you are responsible in any case for the truthfulness and accuracy of the data provided at all times.

3.3. Age and Veracity Control. Sunhero reserves the right to verify your age and identification information at any time, if necessary, even requiring an official document or equivalent procedure and, in case of detection of fraud that proves or is suspected that you are under the age indicated, to delete, temporarily disable and / or cancel your access to the Website.

4. WHAT DATA PROCESSING DO WE CARRY OUT THROUGH THE WEBSITE AND WHAT ARE ITS MAIN CHARACTERISTICS?

Below, we explain how we process your personal information and provide you, in detail, with all the relevant information regarding your privacy:

4.1. When you contact us through our channels (contact form, chat, email):

4.2. When you sign up for our newsletter and other commercial communications:

4.3. When browsing through the Website (cookies)

We use cookies or other tracking and tracing tools on this Website to collect information about how users use the Website. For more information on how we treat such tracking tools, please see ourCookies Policy.

4.4. When you contact us through our social networks.

‍Sunhero has a profile on the main social networks, such as Facebook, Twitter, Instagram, Linkedin or YouTube.

When you become a follower of any of our pages on social networks, the processing of data will be governed by the terms of use, privacy policies and access regulations belonging to the corresponding social network and previously accepted by the user.

Sunhero, in this sense, will process your data for the purposes of properly managing its presence in the social network, informing you of activities, products or services, as well as for any other purpose that the regulations of social networks allow.

Please note that we have no influence over the information that the social network collects or how it processes it, so we recommend that you keep yourself informed of the purpose and scope of the collection of information that is carried out through these social networks.

5. WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?

In general, Sunhero will not disclose your data to third parties. However, here we inform you of the disclosures that we can carry out, in general, and that affect all of the above processing and its legitimate basis:

1. Sunhero Group companies: We can disclose your personal information to the parent company of the Sunhero group: Sunhero GmbH, registered at the Commercial Registry of the District Court of Charlottenburg under the number HRB 226133 B, whose offices are located in Saarbrücker Str. 34 - 10405 Berlin, Germany. These transfers of personal data will be carried out for internal administrative purposes, based on the companies’ legitimate interests. If you would like more information about the analysis carried out by Sunhero, you can request it by writing to us at contact@sunhero.com.
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2. Essential Service Providers to carry out the service we offer you (for example, hosting companies or mailing platforms). Notwithstanding the above, these entities have signed the corresponding confidentiality agreements and will only process your data in accordance with our instructions and may not use them for their own purposes or for purposes other than the service they provide us with.
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3. Public Institutions. We may disclose the data and any other information in our possession or accessible through our systems to the competent public authorities when there is a legal obligation to do so, as well as when required, for example, when the purpose is to prevent or prosecute abuse of services or fraudulent activities through our Website. In such cases, the personal data you provide to us will be retained and made available to administrative or judicial authorities.
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4. In the event of a corporate transaction: In the event of a merger, acquisition, sale of all or part of Sunhero’s assets or any other type of corporate transaction involving a third party, we may share, disclose or transfer your information to the successor entity (including during the pre-transaction phase) only to the extent it is necessary to the correct execution of the operation.
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5. To third parties after aggregation or anonymisation: we may disclose or use aggregated or anonymised data (i.e. data which is not linkable to an identified or identifiable natural person) for any purpose.
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6. To third parties with user consent or other legitimate basis: In the event that we wish to share data with third parties outside the scope of this Privacy Policy, we will always seek your consent or disclose your consent and legitimate basis.

6. ARE YOUR PERSONAL DATA TRANSFERRED TO THIRD COUNTRIES OUTSIDE THE EUROPEAN ECONOMIC AREA?

Some of our service providers are located in countries outside the European Economic Area ("EEA").

The location of these companies outside the EEA implies the existence of an international transfer of your personal data, which could imply a lower level of protection than that provided for in the European regulations. However, Sunhero has implemented measures to ensure that such transfers do not result in a lower level of protection of your personal data.

In this sense, service providers outside the EEA have signed the corresponding standard contractual clauses approved by the European Commission ("SCC"), an agreement signed between both entities by which the non-EU company guarantees that it applies European data protection standards.

Therefore, the use of these providers does not result in a lower level of protection of your personal data than the use of providers located in the European Union. You can consult the content of the SCCs at the following link:

‍https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/rules-international-data-transfers_en

7. WHAT RIGHTS CAN YOU EXERCISE AS A DATA SUBJECT?

You can exercise the rights guaranteed to you by law in relation to the processing of your personal data by contacting us / our Data Protection Officer via the email address contact@sunhero.com.

Any request for rights that we receive will be dealt with as soon as possible and, in any case, within the maximum period permitted by law after we receive it. In some cases, we may need to ask you for a copy of your ID card or other identifying document if we need to verify your identity.

The rights that correspond to you as data subject are as follows:

1. Right to withdraw your consent
   
   ‍You may withdraw your consent in relation to all processing based on it at any time. However, withdrawal of consent will not affect the lawfulness of the processing based on the consent prior to its withdrawal.
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2. Right of access
   
   ‍You have the right to know what data is being processed, if any, and, if so, to obtain a copy of it, as well as to obtain information relating to:

   • the origin and recipients of the data;
   • the purposes for which the data are processed
   • whether an automated decision-making process, including profiling, is involved
     
   • the data retention period; and
     
   • the rights provided by law.
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3. Right of rectification
   
   You have the right to obtain rectification of your personal data or to supplement your personal data where it is incomplete.
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4. Right to erasure
   
   You have the right to request the deletion of your personal data if they are no longer necessary for the purpose for which they were collected or if we are no longer authorised to process them.
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5. Right to data portability
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   You have the right to request data portability in the case of processing of your data that is based on your consent or the performance of a contract, provided that the processing has been carried out by automated means. In case of exercise of this right, you will receive your personal data in a structured format, commonly used and readable by any electronic device. However, you may also request, where possible, that your data be transmitted directly to another company.
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6. Right to limit the processing of your personal data
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   You have the right to limit the processing of your data in the following cases:

   1. Where you have requested rectification of your personal data during the period in which we verify their accuracy;
   2. When you consider that we are not authorised to process your data. In this case, you may ask us to restrict their use instead of requesting their deletion;
   3. When you consider that it is no longer necessary for us to continue processing your data and you want us to keep them for the purpose of exercising or defending claim;
   4. Where there is a processing based on our legitimate interests and you have exercised your right to object to such processing, you may ask us to restrict the use of your data during the verification of the prevalence of those interests over your own.

7. Right to file a complaint with the Data Supervisory Authority
   
   Remember that, at any time, and in the event that you consider that we have infringed your right to the protection of your personal data, you may address your defence to the corresponding Supervisory Authority, in the case of Spain, the Spanish Data Protection Authority (www.aepd.es).
   

8. Right to object
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   You have the right to object at any time to the processing of your personal data based on our legitimate interest, including profiling.
   
   ‍Opt-out of our commercial communications: Remember that you may at any time opt-out of receiving such communications by sending us an email to contact@sunhero.com. You may also opt out of this service by following the instructions indicated at the bottom of the body of each of the electronic communications we send you.
   

8. HOW DO WE GUARANTEE THE CONFIDENTIALITY OF YOUR INFORMATION?

The security of your personal data is a priority for us. For this reason, Sunhero has implemented all the necessary security measures to guarantee an efficient use and treatment of the personal data provided by the user, safeguarding the privacy, confidentiality and integrity of the same and uses the necessary technical means to avoid the alteration, loss, unauthorised access or treatment of your data, according to the state of the technology at any given moment.

Consequently, we comply with the security standards recommended to protect them. However, it is impossible to guarantee total security because of the nature of the Internet and because there may be malicious acts by third parties beyond our control.

We undertake to act promptly and diligently in the event that data security is compromised, and to inform you if relevant.

9. MODIFICATIONS TO THIS POLICY

We can modify the content of the privacy policy at any time, especially when there are changes in legislation, jurisprudence or interpretation of the Data Protection Authorities that affect the data processing carried out by Sunhero through this Website.

Therefore, we recommend that you periodically review this Privacy Policy to be informed of how your personal data is processed and protected, as well as the rights you have.This

Privacy Policy was updated on 30 April 2021.