Privacy Policy
Last updated: 01/11/2025
Identification of the Data Controller
Identity: SUBETE AL TRAAM SL (hereinafter, "Traam")
Registered office: Carrer Pelai 50, 3-2 Barcelona, Spain
Tax Identification Number: B22781074
Email: info@traam.app
Domain name: www.traam.app
Regulatory Framework
The processing of your data and this privacy policy are governed by the current fundamental regulatory framework, without prejudice to the application of development legislation and any other applicable regulations:
General Data Protection Regulation (GDPR): Regulation (EU) 2016/679 of the European Parliament and of the Council, of 27 April 2016.
Organic Law on the Protection of Personal Data and the Guarantee of Digital Rights (LOPDGDD): Organic Law 3/2018, of 5 December.
Law on Information Society Services and Electronic Commerce (LSSICE): Law 34/2002, of 11 July.
Type of Data Collected
As part of the provision of legal services by Traam, the following categories of data will be addressed, by way of example and not limitation:
Identifying Data: Name, surname, NIF/NIE, email, phone number and address.
Transaction Data: Financial and banking information for billing and collecting services.
Contractual and Professional Data: Information necessary for the provision of the legal service related to immigration procedures.
Purposes and Legitimacy of Data Processing
We inform you that Traam will process the personal data you provide to us for the following purposes, justified by the legal basis indicated for each one:
Precontractual and Contractual Purposes
Purpose: To process your data for the generation of estimates, commercial proposals, the management of the client relationship and, in case of contracting, for the effective provision of the foreign affairs management services, as well as billing and collection.
Legal Basis: The application of precontractual measures or the execution of a contract requested by you (Art. 6.1.b GDPR).
Commercial and Promotional Purposes
Purpose: To periodically send commercial and/or promotional communications about services, events, and news related to the activities carried out by Traam.
Legal Basis: The consent of the data subject (Art. 6.1.a GDPR). You may oppose or revoke your consent at any time.
Legal Purposes and Regulatory Compliance
Purpose: To process your data to comply with the duty of information and the transfer of data to authorities when required by law (e.g., tax, accounting obligations, or requirements from public authorities).
Legal Basis: The fulfillment of a legal obligation applicable to the Data Controller (Art. 6.1.c GDPR).
Statistical and Research Purposes
Purpose: To conduct internal studies and statistical analyses on the demand for services and the effectiveness of campaigns, with the aim of improving the quality of Traam's services and the user experience.
Legal Basis: The legitimate interest of Traam (Art. 6.1.f GDPR), provided that the processing is carried out on data that has been pseudonymized or anonymized to the extent possible and that the interests or fundamental rights and freedoms of the data subject do not prevail.
Data Recipients
Your personal data will not be transferred to third parties, except for the execution of the service you have contracted or when required by law. The communication of data is carried out under the following conditions:
National and international authorities competent in matters of immigration:
Purpose: To transfer data to Spanish and international authorities that have competence in immigration matters to carry out the specific tasks that the user has entrusted to Traam in the framework of the service provision.
Purpose and Legitimacy: The transfer is necessary for the execution of the contract (Art. 6.1.b GDPR), as it is an inherent and necessary action for the provision of the entrusted service. If it involves an International Data Transfer to a third country where the GDPR does not apply, that is, outside the EEA, it is covered by the exception of contractual necessity (Art. 49.1.b GDPR).
Traam Service Providers:
Purpose: For the provision of services necessary for the internal operation of Traam (such as, for example, software as a service (SaaS), cloud services, payment gateways, among others).
Legal Guarantee (Contract): Traam implements the obligation for these providers to sign a processing contract. (Art. 28 GDPR).
State Security Forces and Bodies, Banks, Financial Entities, Public Administrations (including the Tax Agency) and Other Competent Authorities.
Purpose: The transfer, in this case, is made to comply with the obligations of collaboration and legal requirements that are mandatory for Traam.
Purpose and Legitimacy: The transfer is legitimized by the fulfillment of a legal obligation (Art. 6.1.c GDPR).
Data Retention Period
Traam will retain users' personal data only for as long as necessary for the purposes for which it was collected:
Data of the Contractual Relationship: It will be retained during the term of service. Once this has ended, the information will be kept blocked for the legally established periods for the handling of potential liabilities and tax, commercial obligations, among others.
Subsequently, after the legal blocking periods have elapsed, the data will be permanently deleted securely.
Data for Commercial Purposes: We will continue to keep your information for sending commercial communications that we consider of interest to you, as long as you do not request its deletion or revoke your consent.
Rights of the Data Subjects
In accordance with current regulations, you have the right to obtain confirmation about the processing of your data and to exercise the following rights:
Access: The data subject will have the right to obtain from the data controller confirmation of whether or not the data concerning them is being processed, as well as detailed information about certain aspects of the processing being carried out.
Rectification: The data subject will have the right to obtain the rectification of inaccurate personal data concerning them or to complete any incomplete data.
Erasure: The data subject will have the right to request the erasure of their personal data; in any case, the erasure will be subject to the limits established in the regulatory standard.
Restriction of processing: The data subject will have the right to request the restriction of the processing of their personal data.
Objection to processing: In certain circumstances and for reasons related to their particular situation, data subjects may object to the processing of their data. The organization will cease processing the data, unless for legitimate, compelling reasons, or for the exercise or defense of potential claims.
Right to data portability: That is, they will have the right to receive the personal data concerning them, which they have provided to a data controller, in a structured, commonly used, and machine-readable format, and to transmit it to another data controller.
Mechanism for the Exercise of Rights: If you wish to exercise any of your rights (access, rectification, erasure, restriction, objection or portability), you must contact the address: info@traam.app .
Important note: To attend to your request, you must attach a copy of an identification document to verify your identity.
Withdrawal of Consent: You may withdraw the consents you have provided at any time, without affecting the lawfulness of the processing based on the consent prior to its withdrawal.
Right to Complain: Furthermore, we inform you that you can contact the Spanish Agency for Data Protection (AEPD) and other competent public bodies for any complaint arising from the processing of your personal data.
Modification of the Privacy Policy
Traam reserves the right to modify this Privacy Policy to adapt it to legislative changes, case law, industry practices, or the company's interests. Any changes to this Privacy Policy will be published on this same website and, in the event that such changes are substantial, will be notified to customers with an active contractual relationship at the time of the update.
We remind you to periodically review this privacy policy to stay informed about how we handle your data.
Our Security Measures
The responsible party has adopted the necessary technical and organizational measures that are appropriate to the level of risk of processing the data and its impact on the rights of individuals in order to guarantee the security of the processing of personal data and that are required at all times by the applicable legislation.
However, the user must be aware that currently, security measures on the Internet are not impregnable and, therefore, one is not safe from possible illegal and undue intrusions, which would not be the responsibility of the organization, as it has at all times acted with due diligence to protect the data in accordance with the law.