Privacy Policy

In SMART PRODUCTS CONNECTION, S.A. we are committed to protecting the privacy and personal data of people who visit our website, purchase our products, use our services, or contact us.

This Privacy Policy explains what personal data we process through www.onspc.com, why we use it, the legal basis that allows us to process it, how long we retain it, to whom it may be disclosed, and what rights you may exercise.

This Privacy Policy applies to data processing carried out through the website www.onspc.com. SPC products, applications, or services that have their own privacy policy will be governed by that specific policy.

1. WHO IS THE DATA CONTROLLER?

The data controller responsible for processing your personal data is:

SMART PRODUCTS CONNECTION, S.A.
Tax identification number: A01042878
Registered office: Leonardo da Vinci, 14, 01510 Miñano, Álava, Spain
Registered in the Álava Commercial Register, volume 364, book 278, section 3, folio 213, sheet 3084, entry 1.
Website: www.onspc.com
Contact email address for data protection matters: dpd@onspc.com

Hereinafter, “SPC”.

2. WHAT PERSONAL DATA DO WE PROCESS?

Depending on your relationship with SPC and the services you use, we may process the following categories of data:

Identification data: first name, surname, and, where necessary, identification document.
Contact details: postal address, email address, and telephone number.
Billing and tax data: billing address, tax identification number, company name, and other information required to issue invoices.
Data related to orders and purchases: products purchased, amount, purchase date, delivery address, returns, incidents, and related communications.
Payment-related data: information required to manage payment for purchases. In general, SPC does not store complete bank card details, which are managed directly by the relevant payment service providers.
Data relating to the user account: credentials, order history, and account-related preferences.
Data derived from inquiries or requests: information you provide when contacting our customer service, technical support, or through other contact forms.
Data used for commercial communications: email address, marketing preferences, and subscription and unsubscribe records.
Technical and browsing data: Technical and browsing data: IP address, online identifiers, device and browser type, pages visited, interactions with the website, and data obtained through cookies or similar technologies, under the terms set out in our Cookie Policy.

Please do not provide us with third parties’ personal data unless you are authorized to do so.

3. WHAT DO WE USE YOUR DATA FOR AND WHAT IS THE LEGAL BASIS?

3.1. Management of purchases and orders

We process the data necessary to:

process and manage your orders;
process the payment;
prepare and deliver the products;
manage returns, exchanges, and refunds;
issue invoices;
keep you informed about the status of your order;
handle incidents related to the purchase.

The legal basis for this processing is performance of the sales contract or the implementation of pre-contractual measures requested by the user.

Likewise, certain data may be processed to comply with our legal obligations, particularly with regard to tax, accounting, consumer protection, and invoicing matters.

3.2. Creation and management of a user account

If you decide to create an account on onspc.com, we will process your data to create it, authenticate you, allow you to manage your data, and provide you with access to your order history and tracking.

The legal basis is performance of the contractual or pre-contractual relationship requested by the user.

3.3. Customer service and support

When you contact us, we will process the data you provide in order to:

handle inquiries;
manage incidents;
provide support;
process complaints;
handle requests related to orders, products, warranties, or services.

When the inquiry is related to a purchase or contracted service, the legal basis will be performance of the contract.

For general inquiries, the legal basis will be our legitimate interest to properly handle the requests we receive and maintain a proper relationship with our users and customers.

3.4. Management of warranties, repairs, and after-sales service

We may process your data to manage legal or commercial warranties, returns, repairs, replacements, and other after-sales services related to our products.

The legal basis will be performance of the contract and, where applicable, compliance with legal obligations applicable to consumers and users.

3.5. Sending commercial communications and newsletters

If you subscribe to our newsletter or tick the corresponding authorization box, we will use your email address to send you information about SPC products, services, news, promotions, discounts, and other commercial communications.

The legal basis will be your consent, which you may withdraw at any time without affecting the lawfulness of processing carried out previously.

Likewise, where there is a prior contractual relationship with SPC, we may send you commercial communications about our own products or services similar to those you have purchased, where permitted by applicable law.

In all cases, you may unsubscribe free of charge using the link provided in each communication or by contacting SPC.

3.6. Fraud prevention and website security

We may process certain data related to operations carried out on the website to detect, prevent, or investigate fraudulent activities, abuse, unauthorized access, or risks to the security of our systems and users.

The legal basis will be SPC's legitimate interest in protecting its business, systems, customers, and users against fraud and unlawful use.

3.7. Compliance with legal obligations

SPC may process and retain certain data when necessary to comply with legal obligations, requests from public authorities, court decisions, or to bring, exercise, or defend claims.

The legal basis will be compliance with a legal obligation and, where applicable, legitimate interest of SPC in exercising or defending its rights.

3.8. Cookies, analytics, and personalization

Where applicable, we may use cookies and similar technologies to analyze website usage, remember preferences, or personalize content and advertising.

Technically necessary cookies may be used to enable the website to function.

The installation of analytics, advertising, or personalization cookies that require authorization will only take place once you have given your consent through the cookie manager.

You can obtain more detailed information in our Cookie Policy.

4. IS IT MANDATORY TO PROVIDE THE DATA?

The fields marked as mandatory in our forms are necessary to provide the requested service.

If you do not provide this data, we may be unable to process an order, create an account, respond to a request, or provide the corresponding service.

The data requested for commercial purposes or for other processing activities based on consent is voluntary.

5. HOW LONG DO WE RETAIN YOUR DATA?

We will retain your personal data only for as long as necessary to fulfill the purpose for which it was collected.

Generally:

Data relating to orders and contracts: for the duration of the contractual relationship and subsequently for the periods necessary to address potential legal liabilities.
Tax and accounting data: for the periods established by applicable tax, commercial and accounting regulations.
Data relating to inquiries and support: for the time necessary to resolve the request and subsequently for the limitation periods applicable to potential liabilities.
Data associated with warranties and after-sales services: for the time necessary to process the service and for the corresponding statutory periods.
Registered user data: while the account remains active and, after its cancellation, for the periods necessary to address potential liabilities.
Data used for commercial communications: until you withdraw your consent or exercise your right to object. We may retain the minimum information necessary to evidence the opt-out and prevent further communications.
Data obtained through cookies: for the periods indicated in our Cookie Policy.

Once the applicable periods have ended, the data may remain duly blocked while legal liabilities may arise and will subsequently be deleted.

6. WHO DO WE DISCLOSE YOUR DATA TO?

We do not sell your personal data.

To carry out our business and provide our services, certain providers may access personal data while acting on behalf of SPC, including providers of:

web hosting and technological infrastructure;
e-commerce platform;
payment services;
transport and logistics companies;
customer service and support services;
email and communications services;
marketing and newsletter management tools;
analytics and measurement services;
IT, maintenance and cybersecurity services;
legal, tax, accounting or administrative advice.

These providers will process the data in accordance with SPC's instructions and will be subject to the applicable contractual obligations regarding confidentiality, security and data protection.

We may also disclose data when necessary to:

banks and payment service providers;
transport companies to make deliveries;
Public Administrations;
judges and courts;
Law Enforcement Agencies;
tax authorities and other competent bodies,
when there is a legal obligation or when necessary for the establishment, exercise or defense of claims.

7. INTERNATIONAL DATA TRANSFERS

Some of our technology providers may be established outside the European Economic Area or use infrastructure located in third countries.

Where this involves an international transfer of personal data, SPC will adopt the safeguards required by applicable law and may, as appropriate, rely on:

adequacy decisions approved by the European Commission;
standard contractual clauses approved by the European Commission;
binding corporate rules;
or other legally valid mechanisms.

Where necessary, additional measures will be adopted to ensure an appropriate level of protection.

You may request additional information about the applicable safeguards by writing to dpd@onspc.com.

8. COMMERCIAL COMMUNICATIONS

SPC will not send commercial communications by electronic means when there is no legal basis permitting it.

When the sending is based on your consent, you may withdraw it at any time.

If you are an SPC customer, we may send you information about our own products or services similar to those you have previously purchased where permitted by law.

All our electronic commercial communications include a simple and free mechanism to unsubscribe.

9. AUTOMATED DECISION-MAKING AND PROFILING

In general, SPC does not make exclusively automated decisions through onspc.com that produce legal effects concerning the user or similarly significantly affect them based on the data processed.

If processing of this kind were implemented in the future, SPC would inform the affected individuals in advance in the manner required by law.

10. WHAT RIGHTS CAN YOU EXERCISE?

You may exercise the rights recognized by data protection regulations at any time.

In particular, you may request:

Access: to find out what personal data we process about you.

Rectification: to request the correction of inaccurate or incomplete data.

Erasure: to request the deletion of your data when the legal requirements are met.

Objection: to request that we stop processing your data in certain circumstances, especially when the processing is based on our legitimate interest or is carried out for direct marketing purposes.

Restriction of processing: to request that we temporarily restrict the processing of your data in the cases provided for by law.

Data portability: to receive certain data that you have provided to us in a structured, commonly used and machine-readable format, or to request its transmission to another controller where legally applicable.

Withdrawal of consent: withdraw the consent you have given at any time. Withdrawal will not affect the lawfulness of processing carried out before such withdrawal.

You may exercise your rights free of charge by submitting a request addressed to:

SMART PRODUCTS CONNECTION, S.A.
Leonardo da Vinci, 14
01510 Miñano, Álava
Spain

or by email at: dpd@onspc.com

The request must enable us to adequately verify your identity and must indicate the right you wish to exercise.

If you believe that the processing of your personal data violates the regulations, you also have the right to lodge a complaint with the competent supervisory authority and, in particular, with the Spanish Data Protection Agency (AEPD).

11. DATA SECURITY

SPC applies technical and organizational measures aimed at protecting personal data against accidental or unlawful destruction, loss, or alteration, as well as against unauthorized access, disclosure, or processing.

These measures are reviewed taking into account the nature of the data, the processing activities carried out, the existing risks, and the state of the art.

However, no information system or data transmission over the Internet can guarantee absolute security.

12. DATA OF MINORS

The onspc.com website and online store are not specifically intended for minors to independently enter into contracts for products or services when they are not legally able to do so.

If SPC detects that a minor's personal data has been provided without a valid legal basis for its processing, it will take reasonable measures to delete it.

Some SPC products or services aimed at minors may have specific privacy policies, which will apply to the processing carried out through those products or services.

13. LINKS TO THIRD-PARTY PAGES

Our website may contain links to websites or services managed by third parties.

SPC does not control the privacy practices of such third parties, so we recommend reviewing their respective privacy policies before providing them with personal data.

14. CHANGES TO THIS POLICY

SPC may update this Privacy Policy to adapt it to legislative changes, criteria issued by supervisory authorities, modifications to our services, or changes in the data processing activities carried out.

When the changes are relevant, we will take reasonable measures to inform users.

The current version will be available at all times at onspc.com and will indicate the date of its last update.

Last updated: October 6, 2026