Privacy Policy

General Privacy Policy of the Tramas Group of Companies

20/02/2026

The Tramas Business Group SL is the CONTROLLER of the USER’s personal data and informs you that such data will be processed in accordance with Regulation (EU) 2016/679 of 27 April (GDPR) and Organic Law 3/2018 of 5 December (LOPDGDD). In this regard, it wishes to inform Data Subjects of the policy implemented concerning the processing and protection of personal data.

We aim to maintain a transparent relationship with you by informing you how we collect and securely process any data you provide to us. To this end, we have drawn up this Privacy Policy (hereinafter, the “Policy”), which will allow you to consult the information you may need and clarify any questions you may have.

Data Protection

Personal Data and guarantee of digital rights.

It is important that you read this Policy carefully, as it will provide you with the necessary information to make an informed decision when providing us with your personal data. You should be aware that this Policy applies to all processing of personal data carried out by any of the companies within the Tramas Business Group SL.

If required by the country in which you are located, this Policy may be supplemented by additional local provisions. This Policy does not apply to third-party websites, including those you may access through a link from our digital environment.

We trust that this information will be useful to you; however, should you need to clarify any additional aspect, you may contact us at protecciondedatos@tramasmas.com.

Who is the Controller of your data?

Each time we collect your personal data, we will inform you which company within the Tramas Business Group is responsible for processing it, including its identification details. We also provide you with the full list of the Group’s companies, all located at Calle Río Viejo 48, 41700 Dos Hermanas, Seville.

• Tramas Home SL: Tax ID B75267880

• Tramas Retail SL: Tax ID B91110528

• Tramas Business Group: Tax ID B90290578

What personal data do we process and how do we obtain it?

By way of example, we process personal data that:

• you voluntarily provide to us

• is derived from access to and use of the service or from the relationship you maintain with us or with any of the group companies, including your image in cases where you have been previously informed of the possibility of image capture

• is derived from communications you maintain with us

• corresponds to your image in video surveillance processing or when you attend an event with a certain public impact, provided that you have been informed of the possibility of image capture

• we may legitimately infer from the data we process

• corresponds to your browsing activity in the case of Online Services, including IP address or information derived from cookies or similar devices (about which you can obtain further details in our Website Cookie Policy)

• corresponds to your social media profiles

• we may legitimately access as information available from publicly accessible sources

• you provide to us regarding third parties, with the prior consent of the Data Subjects

• is provided to us by third parties with your prior consent or where a legitimate legal basis exists.

On what legal basis do we process your personal data?

The processing of your personal data is based on Article 6 of the General Data Protection Regulation (GDPR) as follows:

  1. With the USER’s consent: for sending commercial communications and newsletters.

  2. On the basis of the CONTROLLER’s legitimate interest: to carry out market research, statistical analysis, and manage requests, orders, and procedures carried out by the USER. The processing of your personal data is also intended to manage the relationship you maintain with us, whether as a user of the Online Service, through a contract, or any other type of civil or commercial relationship. We use your data primarily to manage this relationship, issue the corresponding invoices, handle potential debts, and address complaints, claims, questions, or suggestions you send us. The performance of this relationship is the legal basis that allows us to carry out such processing.

What do we process your personal data for?

To maintain a commercial relationship with the user. The processing operations envisaged are:

• Sending advertising and commercial communications by email, SMS, WhatsApp, social media, or any other electronic or physical means, present or future, that enables commercial communications. These communications will be carried out by the CONTROLLER and will be related to its products and services, or those of its collaborators or suppliers with whom it has reached a promotional agreement. In such cases, third parties will never have access to personal data.

• Conducting market research and statistical analysis.

• Processing orders, requests, responding to queries, or any type of request made by the USER through any of the contact methods made available on the CONTROLLER’s website.

• Sending the online newsletter regarding news, offers, and promotions related to our activity.

• Managing the relationship you maintain with us, whether as a user of the Online Service, through a contract, or any other type of civil or commercial relationship. We use your data primarily to manage this relationship, issue the corresponding invoices, handle potential debts, and address complaints, claims, questions, or suggestions you send us. The performance of this relationship is the legal basis that allows us to carry out such processing.

Sharing your data with other companies within the Tramas group

We are interested in ensuring that your relationship with the Tramas group is unified and as comprehensive as possible. Therefore, and only if you provide your consent, we will transfer all your data to the other companies within the Tramas group.

The legal basis that enables this processing is your consent. If you do not provide your consent, we will not carry out this processing.

Managing contact data within the framework of contractual relationships or for the purpose of sending non-commercial information and event invitations may involve processing contact data or data of representatives of third parties with whom we maintain contractual relationships, solely for the purpose of managing the contractual relationship. The legal basis enabling us to process your data in this case is the performance of the contract.

In addition, Tramas may process contact data of potential corporate clients, representatives of institutions, representatives of public bodies, journalists, analysts, or investors who have voluntarily provided us with their data, in order to send them non-commercial information about Tramas and invitations to group events.

The legal basis enabling us to process your data in this case is the Data Subject’s consent, which is expressed by providing us with their contact details.

Candidates

Tramas regularly publishes job offers and provides a channel through which it also receives unsolicited applications. If you contact us expressing interest in joining the Tramas group workforce, we will process your data, together with all documentation you provide, in order to assess your profile and consider you for potential vacancies within the Tramas group. This implies that we will share your information with the group company responsible for the vacancy. The legal basis for this processing is your consent, expressed through the submission of your application.

Security at Tramas group facilities

Tramas has video surveillance cameras intended to ensure the security of the facilities of the group’s companies. The legal basis for this processing is the legitimate interest of the Tramas Business Group in preventing or, where appropriate, investigating possible incidents occurring at its facilities.

Visits and events

Managing visits to our facilities, or individuals who are invited to or register for an event organised or sponsored by the Tramas Business Group, is another type of processing we may carry out. In the case of events, the Tramas Business Group may capture images for the purpose of publicly disseminating the event, which will be communicated to the Data Subject so that they may either decline to attend or exercise their rights. The Data Subject’s consent is the legal basis enabling us to process your data in this case.

How do we process your personal data?

We undertake to process your data in accordance with applicable regulations and, in particular, to process any data to which we have access by applying appropriate technical and organisational measures to ensure an adequate level of security, guaranteeing at all times the ongoing confidentiality, integrity, availability, and resilience of processing systems and services.

To which recipients will your data be disclosed?

No disclosure of personal data to third parties is envisaged, except where necessary for the development and execution of the purposes of the processing, to our service providers related to communications, with whom the CONTROLLER has entered into the confidentiality and data processing agreements required by current privacy regulations.

Whenever we intend to lawfully transfer or disclose your personal data, we will inform you at the time of collection about the identity or categories of recipients to whom we may disclose it, such as:

• Third parties to whom we must disclose your data due to a legal obligation, for example administrative, tax, or social security authorities.

• Third parties with whom we must share your data to confirm your membership of a specific group if you wish to benefit from that group’s offer.

• Entities that subsidise training activities, within the framework of processing for training purposes.

• Third parties to whom we must disclose your data in order to fulfil the essential purposes of the relationship.

• Other companies within the Tramas group, where applicable.

• Other third parties, if you have consented to this.

• Shared credit information files relating to the fulfilment or non-fulfilment of monetary obligations in the event that you fail to meet a payment obligation with any company within the Tramas group.

We also inform you that, in some cases, such access may be carried out by companies located outside the European Union, including in countries with a level of protection not equivalent to that of the European Economic Area. Nevertheless, all international data transfers we may carry out are lawful and covered by one of the safeguard mechanisms established by the GDPR. Below, we provide further information about the international transfers we may carry out:

How long do we retain your personal data?

In each case, we will inform you of the duration of the processing, which will be sufficient to fulfil our obligations to you and to the relevant authorities. When it is no longer necessary for these purposes, the data will be deleted using appropriate security measures to ensure anonymisation or complete destruction. In any event, the personal data you provide to us will be retained for as long as the relationship we maintain with you continues and you do not request its deletion. Thereafter, where applicable, we may retain the data in a blocked form for the statutory limitation periods relating to criminal, civil, commercial and/or administrative liabilities.

In the case of Online Services, the Tramas Business Group will retain your personal data for as long as you remain a user of the Online Services. However, if we detect that for a period of two (2) years you have not used or interacted with your account or any of our Online Services, we will proceed to cancel your account by blocking your data. If you wish to use any of the Online Services again, you will need to register as a new user.

What are your rights when you provide us with your data?

At any time, you may exercise a number of rights regarding the processing of your data. These rights are inherent to each individual and are therefore non-waivable. Below, we describe them and explain what each entails:

• Right of access. By exercising this right, you may obtain information about the processing we carry out on your personal data.

• Right to rectification. You may correct or modify your data if it is inaccurate or incomplete to ensure that the information we hold about you is accurate.

• Right to erasure (or right to be forgotten). You may request the deletion of your personal data where one of the legally established grounds applies, for example unlawful processing or where the purpose that justified the processing or collection has ceased to exist. However, certain exceptions apply where this right will not proceed, such as where the right to freedom of expression and information must prevail.

• Right to object. Through this right, you may object to the processing of your personal data: (i) where, for reasons relating to your particular situation, the processing should cease unless a legitimate interest is demonstrated or it is necessary for the establishment, exercise, or defence of legal claims; or (ii) where the processing is for direct marketing purposes.

• Right to restriction of processing. You may request that we restrict the processing of your data where: (i) you contest the accuracy of the data, while we verify such accuracy; (ii) the processing is unlawful but you oppose the deletion of the data and request restriction instead; (iii) you require the data for the establishment, exercise, or defence of legal claims; or (iv) you have objected to processing carried out in the public interest or based on legitimate interest, pending verification. In such cases, we will only retain the data for the establishment, exercise, or defence of legal claims.

• Right to data portability. You may request the portability of your data in electronic format, as well as the possibility of transmitting it to another entity.

• Right to withdraw consent at any time: you may withdraw the consent given without affecting the lawfulness of processing carried out prior to its withdrawal.

• Right to lodge a complaint with the supervisory authority (www.aepd.es) if you consider that the processing does not comply with current regulations.

To exercise these rights, you may contact GRUPO EMPRESARIAL TRAMAS S.L., Calle Río Viejo 48, 41700 Dos Hermanas, Seville. Email: protecciondedatos@tramasmas.com. Contact details of the Data Protection Officer: José María Jurado, Calle Río Viejo 48, 41700 Dos Hermanas, Seville. Please remember to attach a copy of your ID card or equivalent document and indicate the relevant processing activity.

Can we change the terms of the Policy?

We may modify this Policy at any time, but we will always inform you of any significant changes through the corresponding notice. Whenever we make minor changes to our Privacy Policy, we will update it with a new effective date included in the document. The processing of your data will be carried out in accordance with the new version of the Privacy Policy from its effective date onwards. We recommend that you review the Policy periodically.

What are your responsibilities?

You are responsible for the accuracy, truthfulness, updating, validity, and authenticity of the data you provide to us, as well as for the consent you grant us for its use and processing. In addition, you are responsible for periodically reviewing this Privacy Policy and any updates that may be made to it.

By checking the corresponding boxes and completing the fields marked with an asterisk (*) in the contact form or download forms, USERS expressly, freely, and unequivocally accept that the requested data is necessary to process their request by the service provider. The inclusion of data in fields not marked as mandatory is entirely voluntary. The CONTROLLER clarifies that all data requested through the website is essential, as it is necessary to provide an appropriate service. If all required data is not provided, it cannot be guaranteed that the information and services supplied will be fully tailored to the USER’s needs.

The sending of commercial communications will always require your express consent, which you may withdraw at any time without affecting the performance of any contracts you maintain with us.

The Tramas Business Group wishes to inform data subjects about its policy regarding the processing and protection of personal data. We aim to maintain a transparent relationship with you by informing you how we collect and securely process any data you provide to us. For this reason, we have drawn up this Privacy Policy (hereinafter, the “Policy”), which will allow you to access the necessary information and resolve any questions you may have.

Likewise, we inform you that your data will be processed in accordance with current personal data protection regulations, specifically Regulation (EU) 2016/679 of 27 April 2016 (GDPR), concerning the protection of natural persons with regard to the processing of personal data and the free movement of such data, as well as Organic Law 3/2018 of 5 December on Personal Data Protection

Personal Data and guarantee of digital rights.

It is essential that you read this Policy carefully, as it contains the information necessary for you to make informed decisions when providing us with your personal data. This Policy applies to all processing of personal data carried out by any of the companies within the Tramas group. In some cases, if the local regulations of the country in which you are located so require, it may be supplemented with additional provisions. However, it does not apply to third-party websites, including those you may access through links from our environment.

The CONTROLLER ensures compliance with current personal data protection regulations, such as the GDPR and the LOPDGDD, in the processing of data under its responsibility. The processing is carried out in accordance with the principles set out in Article 5 of the GDPR, ensuring that data is processed lawfully, fairly, and transparently, and that it is adequate, relevant, and limited to what is strictly necessary for the intended purposes.

In addition, the CONTROLLER has implemented appropriate technical and organisational policies to comply with the security measures required by the GDPR and the LOPDGDD, with the aim of protecting the rights and freedoms of USERS and ensuring that they have access to the necessary information to exercise those rights.

We hope this information is useful to you. If you need to clarify any additional aspect, you may contact us at protecciondedatos@tramasmas.com.