Privacy Policy

Last updated: March 23rd, 2026

Who is responsible for processing your data?

Cluber Siguetuliga, S.L. (hereinafter ‘Cluber’)
Telephone: 881 55 71 65
Email: protecciondatos@cluber.com

Contact details of the Data Protection Officer

dpd@cluber.com

From whom do we obtain personal data?

The personal data processed via our website (the “Website”) is provided directly by the user via the forms provided for this purpose or through the communication channels detailed in each section of the site.

The user guarantees that the data provided is true, accurate and complete, and undertakes to keep the information provided suitably up to date so that it reflects their actual situation.

Should the user provide data relating to third parties, they declare that they have a legal basis for doing so and undertake to convey the provisions contained in this privacy policy, thereby exempting CLUBER from any liability in this regard.

The data in the forms provided on the Website that are marked with an asterisk (*) are necessary to fulfil the purpose for which the data is collected. If this data is not provided, it may not be possible to fulfil the purpose

What categories of data do we process?

Taking into account the various purposes, different categories of data will be processed:

Identification and contact details: first name and surname, email address, postal address and telephone number.
Employment details: professional category, job title, company where you work and corporate contact details.
Browsing data: IP address, device ID.
Other data: Any data provided by the user during interactions or communications (contact forms, chatbot, etc.)

For what purpose will we process personal data?

The data will be used for the following purposes:

Contracting and subsequent customisation of the application
Access, use and management of the Club via the platform, in accordance with the contracted modules
To manage and respond to contact requests, either via the forms provided for this purpose on the Website, corporate email addresses or other means of contact used for this purpose.
To periodically send commercial and/or promotional information relating to the contracted services and value-added services, via electronic and/or conventional means, unless otherwise indicated or the user objects or withdraws their consent.
To comply with legally established obligations, as well as to verify compliance with contractual obligations, including fraud prevention.

What is the legal basis for each processing operation?

We process data in accordance with the following legal bases:

Performance of a contract: For the conclusion, customisation, as well as access to and use of the platform.
Consent: For the management and handling of contact requests. Should consent be withdrawn, the enquiry or issue raised cannot be processed.
Compliance with a legal obligation: For all processing operations required by national or regional laws
Legitimate interest: Covers the sending of electronic marketing communications, as well as the conducting of quality and satisfaction surveys relating to quality and satisfaction

How long is the data processed for?

These are the retention periods:

Contract and use of the platform: Data will be retained for the duration of the contractual relationship and, once this has ended, for the period established by law, including tax and accounting regulations, amongst others.
Contact requests: data will be retained for the period necessary to process the response and, once processed, will be kept on hold for the limitation period of any legal actions that may arise.
Sending of marketing communications: Data will be retained until consent is withdrawn or we receive an objection to such communications.
Legal obligations: In accordance with the time limits set out in the applicable legislation.

We do not share data with third parties, except in the following cases:

Banks and financial institutions for the collection of payments for the use of the Platform
Public authorities, courts and tribunals, and law enforcement agencies, where required to do so and always in accordance with legal provisions

What rights does the data subject have?

Any person may, within the terms and limits set out in the legislation, exercise their rights of access, rectification, erasure, objection, restriction of processing and data portability by writing to protecciondatos@cluber.com.

Furthermore, a complaint may be lodged with the Spanish Data Protection Agency should the data processing be deemed inappropriate. This procedure is available on their website at https://sedeaepd.gob.es/sede-electronica-web/

Changes to the privacy policy

To ensure that this Policy always complies with the established legal requirements, we will make the necessary changes to bring it into line with current legislation.

Last updated: 23 March 2026.