Legal

Privacy Policy

Last updated: November 30, 2024

1. Introduction

NaturaGas ("we", "our", or "us") is committed to protecting the privacy and security of personal data. This Privacy Policy explains how we collect, use, share, and protect information in relation to our gas import and distribution services.

We comply with:

  • EU General Data Protection Regulation (GDPR) - Regulation (EU) 2016/679
  • Spanish Organic Law 3/2018 on Data Protection (LOPDGDD)
  • Spanish Law 34/2002 on Information Society Services (LSSI-CE)

2. Data Controller

The data controller responsible for your personal data is:

Company: NaturaGas

CIF: B-12345678 (Example)

Email: privacy@naturagas.com

Data Protection Officer: dpo@naturagas.com

3. Information We Collect

3.1 Business Contact Information

We collect information necessary for business relationships:

  • Company details: Business name, tax ID (CIF/NIF), registration number, industry sector
  • Contact persons: Names, job titles, email addresses, phone numbers
  • Business address: Delivery addresses, billing addresses, facility locations
  • Financial information: Bank details for payments, credit references

3.2 Transaction Information

  • Purchase orders and order history
  • Product specifications and quantities
  • Delivery schedules and locations
  • Invoices and payment records
  • Contract terms and pricing agreements

3.3 Technical Information

  • Website usage data (IP address, browser type, pages visited)
  • Cookies and similar tracking technologies
  • Email open rates and click-through rates
  • Communication logs and timestamps

3.4 Safety and Compliance Information

  • Safety certifications and permits
  • Facility inspection reports
  • Training records for authorized personnel
  • Incident reports and safety documentation

4. How We Use Your Information

4.1 Contract Performance

Legal basis: Performance of contract (GDPR Article 6(1)(b))

  • Processing and fulfilling orders
  • Arranging deliveries and logistics
  • Managing customer accounts
  • Invoicing and payment processing
  • Providing customer support

4.2 Legal Obligations

Legal basis: Compliance with legal obligations (GDPR Article 6(1)(c))

  • Tax reporting and accounting (Spanish Tax Agency requirements)
  • Safety compliance and documentation (Spanish ITC regulations)
  • Anti-money laundering checks
  • Customs and import documentation
  • Maintaining records per legal retention requirements

4.3 Legitimate Business Interests

Legal basis: Legitimate interests (GDPR Article 6(1)(f))

  • Credit assessment and risk management
  • Business development and market research
  • Fraud prevention and security
  • Improving our services and operations
  • Internal administration and IT systems
  • Professional advice (legal, accounting, consulting)

4.4 With Your Consent

Legal basis: Consent (GDPR Article 6(1)(a))

  • Marketing communications and newsletters
  • Product updates and service announcements
  • Industry insights and educational content

You may withdraw consent at any time by clicking "unsubscribe" in our emails or contacting us directly.

5. Information Sharing

5.1 Service Providers

We share data with trusted third parties who assist in our operations:

  • Logistics partners: Transportation and delivery services
  • Payment processors: Banks and payment service providers
  • IT service providers: Cloud hosting, CRM systems, email services
  • Professional services: Legal, accounting, auditing firms

All service providers are bound by data processing agreements and GDPR requirements.

5.2 UAE Suppliers

We share necessary business information with our UAE gas suppliers for order processing, product specifications, and shipping documentation. International transfers to UAE are protected by Standard Contractual Clauses (SCCs) approved by EU Commission.

5.3 Regulatory Authorities

We may share information with Spanish Tax Agency, Ministry of Industry, Spanish Data Protection Agency (AEPD), port authorities and customs agencies, and safety regulators.

6. Data Security

We implement appropriate technical and organizational measures including encryption, secure cloud infrastructure, regular security audits, firewall protection, multi-factor authentication, employee training, and data breach response procedures.

7. Data Retention

We retain personal data only as long as necessary:

  • Contact information: Until customer requests deletion or 3 years of inactivity
  • Transaction records: 6 years (Spanish tax law requirements)
  • Accounting records: 6 years per Spanish Commercial Code
  • Marketing data: Until consent is withdrawn or 2 years of no engagement

8. Your Rights

Under GDPR and Spanish data protection law, you have the following rights:

  • Right of Access (Article 15): Request a copy of personal data we hold about you
  • Right to Rectification (Article 16): Correct inaccurate or incomplete personal data
  • Right to Erasure (Article 17): Request deletion of personal data
  • Right to Restriction (Article 18): Request limitation of processing
  • Right to Data Portability (Article 20): Receive your data in a structured format
  • Right to Object (Article 21): Object to processing for direct marketing

To exercise any of these rights, email us at privacy@naturagas.com. We will respond within 30 days.

9. Cookies and Tracking

We use essential cookies (required for functionality), analytics cookies (Google Analytics), functional cookies (preferences), and marketing cookies (with consent). You can control cookies through our consent banner or your browser settings.

10. International Transfers

When we transfer data outside the EEA, we use Standard Contractual Clauses (SCCs) approved by the European Commission and ensure adequate technical and organizational safeguards. Primary non-EEA transfers: United Arab Emirates (for supplier coordination).

11. Changes to This Policy

We may update this Privacy Policy to reflect changes in our practices, legal requirements, or technology. Material changes will be communicated via website notice (30 days before effective date) and email notification to active customers.

12. Complaints

If you believe your data protection rights have been violated, contact us first at privacy@naturagas.com. You also have the right to lodge a complaint with the Spanish Data Protection Agency (AEPD):

Agency: Agencia Española de Protección de Datos (AEPD)

Address: C/ Jorge Juan, 6, 28001 Madrid, Spain

Phone: +34 901 100 099

Website: www.aepd.es

Email: internacional@aepd.es

13. Contact Information

For privacy-related inquiries:

Role: Data Protection Officer

Company: NaturaGas

Email: dpo@naturagas.com

Privacy inquiries: privacy@naturagas.com

This Privacy Policy is provided in accordance with Articles 13 and 14 of the GDPR and Spanish data protection legislation. By using our services, you acknowledge that you have read and understood this Privacy Policy.