At SURUS INVERSA S.L we know the importance of your data, therefore we establish the most strict security measures and we only use your information for clearly described purposes.
We made all efforts to create a reliable and safe space, which is why we want to share with you our principles regarding privacy:
We never request any personal information unless it is necessary for offering our services.
We never share personal information from our users with anyone, unless we need to comply with any law or we have your express consent.
SURUS INVERSA S.L complies with Spain’s organic law (15/1999) from December 13th about Personal Data Protection, with the Royal Decree 1720/2007 from December 21st for the approval of regulations on the development of the Organic Law, as well as European regulations 2016/679 from the European Parliament on April 27th 2016 regarding data protection for physical individuals, and with Law 34/2002 from July 11th of Services from Information Society and E-Mail (LSSI).
Responsibility of handling
Identity: SURUS INVERSA SL
Fiscal Identification Code: B86058567
Address: Camino de las Huertas, 18, 2º Pl, 28223 Pozuelo de Alarcón, Madrid
Phone number: 913 524 507
E-mail address: email@example.com
Principles we apply to your personal information
When handling your personal data, we apply the following principles which comply with current rules from the European General Data Protection Regulation:
- Principle of lawful, fair and transparent processing: We will always ask for your consent when handling your personal data for one or more specific purposes, which will be notified to you previously with complete transparency.
- Principle of data minimization: We will only request strictly necessary data according to the purposes of the request. As few as possible.
- Principle of limited storage time: Your data will be stored as long as it is necessary for their purpose. We will inform you about the corresponding period of time. In case of subscribers, we regularly revise our lists and remove users inactive for a long period of time.
- Principle of integrity and confidentiality: Your data will be handled in a way that ensures safety and confidentiality for your personal information. Please be aware that we take all necessary measures to prevent non-authorized access or misuse of data from our users from third parties.
Products and services from SURUS INVERSA S.L, as well as marketing campaigns, are addressed to adults. We only collect and handle your personal information if you are at least 16 years old. Any data from someone younger than 16 years old will be removed.
If you are less than 16 years old and access this website, you should not register as user.
How we collect personal data in this website
- Every time you register in our website.
- When browsing our website.
- When filling a contact form with your personal information.
- When participating in our direct marketing campaigns.
- When third-parties share your personal data with your authorization.
- When commenting through the blog.
- When participating in our social networks.
- When filling a form showing interest in specific products or items.
- When requesting additional information about a product to Surus Inversa S.L. employees.
- When requesting information about a product in Escrapalia.com that you have seen in our digital marketing campaigns or ads in other platforms.
We appreciate that you help us keep your personal information updated. Let us know about any change in your contact information or preferences.
Which information we collect
Every time you access SURUS INVERSA S.L, in the CONTACT section, you are required to provide the following information:
First and Last names or Company
Physical and online addresses
Phone number (Home and Mobile)
Language for communications
In case you want to sell something: position, number of employees, type of assets and
How many do you want to sell?
Following the statements declared on article 21 of the LSSI regulation, we inform you that when a previous contractual relationship is in place, all email data provided by the user can be used for sending commercial communications regarding products or services related to the contract with the user.
Why we handle your data
We use your data for different purposes, which we will describe in this section.
- SURUS INVERSA S.L collects your contact data, information about your preferences and data about the use of websites and communications. Escrapalia can also use information about purchases or bids you make to determine those products that can be interesting to you and to contact you depending on your preferences.
- SURUS INVERSA S.L can also use your personal data to develop individual user profiles through statistical processes. As a result of the development of profiles, you can receive customized communications related to contents of your interest.
- For sending information requested by the user.
- Complying with legal regulations: in order to comply with legal regulations about information requests from legal institutions, regulatory organizations and law enforcement departments.
- Everyone involved in the handling of data is subject to laws that apply in the country they work in and are obliged to comply with them. These obligations include the transmission of personal data to legal institutions, regulatory organizations and law enforcement departments in special circumstances. SURUS INVERSA S.L is legally compelled to hand over this information to those organizations.
- There are other purposes for the handling of your personal data:
- To ensure compliance with conditions of use and applicable laws. This may include the development of tools and algorithms that help this website ensure confidentiality of the personal data collected.
- To support and improve services offered by this website.
Remarketing allows us to reach people that have previously visited Surus Inversa S.L and associate a determined audience to a specific message. Remarketing is a way to make users who visited our website do it again.
As a user of Surus Inversa S.L, we inform you that we are collecting information for this remarketing function at surusinversa.com.
This information is collected by cookies from service providers. For more information about data collected by these cookies, check the Privacy Policies of these services:
- Facebook / Instagram
- Google associated services
If you don’t want cookies to collect this information, you can disable the use of Google cookies through Google’s advertising settings. Location.
These type of services allow interaction with social networks and other external platforms directly from the pages of this website. Any interaction and information collected by this website will always be subject to the privacy settings of the user in each social network. In case a service for interacting with social networks is installed, there is a possibility that it collects information about web browsing even for users that are not using that service.
Advertising through other platforms
Surus Inversa S.L uses advertising platforms with the following providers to generate ads and campaigns:
- Facebook / Instagram
- Google associated services
- Other platforms: Milanuncios, Mascus, Machinery Trader, Autoline, Interempresas, Autocasión, Fotocasa, Idealista
When generating ads, the audience can be segmented by:
- Demographic data (age, gender, etc.)
- Interests (activities, hobbies, etc.)
- Their purchases on the Internet and other channels
How long your data is stored
If your data is used for different purposes which imply different storage periods, we will apply the longest storage period.
Your personal data will be stored as long as the user does not request removal.
In any case, we limit the access to your data to those people that need to use for their working purposes.
Regarding information that is no longer necessary, either access will be limited to complying with legal obligations or they will be safely removed.
Marketing purposes: regarding the use of your information for marketing purposes, we will keep this information for that purpose during the next five years after you have authorized the receipt of communications for the last time, unless you request to be removed from them revoking the previous consent. Purposes related to the compliance with legal and regulatory obligations: specific information will be stored for as long as it is required by any applicable law (taxing, commercial, money laundering, etc.).
Data protection measures
We use several protection measures to ensure the safety, integrity and availability of your data. Even though it is impossible to ensure complete safety during the transmittal of data through Internet or any website against intrusions, both us and any outsourced or partner companies place all efforts to ensure physical, electronic and procedural protection measures to ensure data protection according to any applicable legal requirement. Amongst others, we use the following measures:
- Limiting the access to your data only to those people that must do so according to their functions and who have signed a confidentiality agreement.
- Storing sensible data (such as credit cards) only in encoded format.
- Installing perimeter protection systems in computer structures (firewalls) to prevent unauthorized accesses, e.g. from hackers.
- Monitoring regularly the access to computer systems to detect and prevent any misuse of personal information.
- Handing a manual about Use Policies and information technologies control to any employee in our organization with access to information
- Implementing an Information Security System complying with UNE-EN ISO 27001 regulations and yearly audited by a certified organization.
In case we have given you (or you have chosen) a password for accessing specific parts of our websites or any other portal, app or service under our control, you are responsible of keeping it secretly and complying with any safety processes we notify to you. You cannot share your password with anyone
Rights of users
We remind you that your rights are guaranteed. These are your rights:
- Obtaining confirmation on whether or not Surus Inversa S.L is handling your personal data.
- Obtaining more details about how we use your information.
- Accessing your personal data and requesting their modification or removal when, amongst other reasons, the data is no longer necessary for the purposes they were collected.
- In some circumstances, users can request a limited handling of their data. In that case, we will only keep them for claiming purposes.
- Revoking your consent for the handling of data for those purposes, in those cases where data handling depends on consent, as well as any marketing communication.
- In some circumstances, users can deny data handling (including profiling). Surus Inversa S.L will no longer handle data except for imperative legal reasons, or defending against potential claims.
- Requesting the transmittal of data.
- Users will also have the right to a proper legal consultancy and to present a claim to the authorities (in this case, the Spanish Data Protection Agency) if they consider that their personal data is used against any regulations.
Exercising these rights from your side is subject to special circumstances of general interest (e.g. for the prevention or detection of crimes) or for our own interest (e.g keeping legal advice confidentiality). If you exercise any of these rights, we will make sure you are authorized to do so and will reply to you in a month or in the longest time allowed by Spanish laws in case it is shorter.
The use of your data according to previously described conditions complies with Spanish and European data protection regulations, following this legal basis:
- You give your consent (You have authorized the handling of your data for specific purposes through a consent form and may revoke this given consent at any time).
- Handling your data is necessary to manage a contract signed with you.
- Handling your data is necessary to comply with our legal obligations.
- We use your information for a lawful purpose and our reasons to do it balance potential damage to your data protection rights.
Many tools we use to handle your data are outsourced to a third party.
In order to offer services which are completely necessary for developing its activities, Surusinversa.com shares information with the following providers under their own privacy conditions:
Google Analytics: Web analysis service offered by Google Inc., a company based on Delaware and whose headquarters are located in 1600 Amphitheater Parkway, Mountain View (California), CA 94043, USA (“Google”). Google Analytics uses “cookies”, text files located in your computer to help Surusinversa.com analyze the use of the website by users. Information generated by cookies about the use of Surusinversa.com (including your IP address) will be directly transmitted and archived by Google in their servers in the USA.
Hosting: GoDaddy.com, LLC. Is based in the USA. More information in https://es.godaddy.com/ GoDaddy.com, LLC handles data in order to provide hosting services to Surusinversa.com platform.
User segmentation Piperlab, S.L, based in Spain, uses information gathered through Zoho Corporation tools to determine those products that can be interesting to you according to the preferences you show when interacting with Surusinversa.com (e-mail marketing campaigns, web browsing, etc.). For more information, see https://piperlab.es/aviso-legal/.
Microsoft Azure: Cloud infrastructure where Escrapalia’s website is hosted and therefore its databases and programming code. We data such as lots, bids, users and their data are stored there, complying with their policies on privacy and data handling. For more information, check https://azure.microsoft.com/es-es/
If you have any question about the use we make of your information, please contact us through the e-mail firstname.lastname@example.org
If you are not satisfied with the way we use your information or the way we respond to the exercise of any of these right, you can submit a complaint to the Spanish Data Protection Agency (www.agpd.es).
SURUS INVERSA S.L. is a private company specialized in recapturing value through reverse logistics and the sale of obsolete material, stock surplus, end-of-life products and scrap to secondary markets with the aim of maximizing returns for their clients. We are determined to extract value from unused waste from any origin, including waste generated from the dismantling of a ship, and to make sure that waste is properly managed. We know how wrongful waste management can impact the environment.
A key part of our business strategy is the commitment with the protection of the environment, taking every necessary action to minimize impacts, prevent pollution, and enforce safety and health measures for our workers. Furthermore, we have developed an Anti-bribery and Compliance Model, determining an ethical and behavioral code, mandatory for all employees of our company and other companies working for or in name of SURUS INVERSA S.L. The goal is to prevent any act against the law, including briberies and other similar acts. It is carried out with security guarantees of the information and the data that SURUS INVERSA S.L works with.
In this context, the company is committed to:
- Understand the needs of our clients and to satisfy them.
- Comply and ensure compliance with all laws and regulations applicable for the different activities developed by the company, as well as any other requirement from our clients or from the inside of the company.
- Anticipate to any health damage by establishing a safety in the workplace system based on prevention and/or removal of risks in all work positions.
- Determine a commitment to provide safe and healthy working conditions for the prevention of injuries and deterioration of health related to the job of our workers.
- Identify hazards and reduce risks for Safety and Health at Work, eliminating the danger whenever possible, substituting processes, operations, materials or equipment for less dangerous ones whenever possible, providing the appropriate personal protective equipment to our workers.
- Workers will be duly informed and instructed on the rules and preventive measures in force for their work, and will participate in all matters that affect safety and health at work.
- Protect the company’s information resources and the processing technology from external or internal, meant or unmeant threats in order to ensure the compliance of clauses of nondisclosure, authenticity, traceability, availability, legality and reliability of information.
- Commitment that both the Management and its staff must apply the established information security measures and establish the control and monitoring mechanisms thereof. For this, the company has implemented a set of objectives, measures, controls, procedures and actions aimed at protecting all assets, including both the information, the processes, the systems and the networks that support it. Our entire information security management system is based on continuous improvement.
- Keep continuous improvement in all processes, developing corrective and proactive measures to prevent error recurrence.
- Promote training and awareness actions for employees in order to improve their performance within the company and ensure the achievement of goals and milestones.
- Identify activities where crimes can be committed in the Guidelines for the Prevention of Criminal Offenses.
- Determine general policies, procedures, and mandatory regulations regarding information safety, correct management and anti-bribery, which will be spread to all employees at the company and all stakeholders.
- Forbid any behavior in conflict with the General Anti-bribery and Compliance Regulations. Disciplinary, corrective or penalty measures according to current work laws will be applied if necessary.
- Develop a channel to lodge a complaint for all employees within the organization and any external person that must share any piece of information, doubt or suspicion about a behavior that goes against our ethical code or the law. The email address email@example.com has been enabled for this or by post to Camino de las Huertas 18, 2º Pl. (28223 Pozuelo de Alarcón). In any event, retaliation of any kind against a reporter in good faith is prohibited.
- Employees at Surus are never allowed to promise, offer or give a bribe;
- Employees at Surus are never allowed to ask for or accept a bribe;
- Establish a Compliance committee, independent from any business decision, whose goal will be to monitor and control the Anti-bribery and Compliance Model, as well as to report about and manage any issue related to the Model.
- Determine ways for the notification, management and registry of incidences related to any of the management systems implemented in the organization.
- Manage all systems according to the principles of risk management, focusing on preventive measures over corrective actions.
- Consider management planning as an integral part in all processes within the organization, determining regular programs, goals and objectives to guarantee the compliance of the Policy and the continuous improvement of the integral management system.
Management extends this commitment to all employees and any person that acts on behalf of SURUS INVERSA S.L, who shall comply with this policy guidelines, which will be revised regularly in order to ensure they are appropriate for the activities of the organization.
Madrid, 03 March 2021
Surus Inversa S.L